40-17G 1 a09-3198_114017g.htm 40-17G

 

WESTERN ASSET MUNICIPAL DEFINED OPPORTUNITY TRUST INC.

55 Water Street

New York, New York 10041

 

April 6, 2009

 

Securities and Exchange Commission

100 F Street, N.W.

Washington, D.C. 20549

 

Re:

Western Asset Municipal Defined Opportunity Trust Inc.(the “Fund”)

 

File No. 811-22265

 

Rule 17g-1 Notice - Fidelity Bond Coverage

 

Dear Sir or Madam:

 

Pursuant to the provisions of Rule 17g-1 under the Investment Company Act of 1940, please be informed that the Fund has been added to the joint fidelity policy of registered investment management companies (the “Companies”) managed by Legg Mason Partners Fund Advisor, LLC.

 

The coverage in place for the Companies as of July 15, 2008, is under a policy from ICI Mutual Insurance Company.

 

This filing represents the addition of one new fund:

 

Western Asset Municipal Defined Opportunity Trust Inc.

 

Enclosed are:

 

1.     An amendment to Schedule I of the recovery allocation agreement.

 

2.     A copy of resolutions adopted by a majority of the Board of the Fund who are not “interested persons” approving the amount, type, form and coverage of the bond and the portion of the premiums to be paid by the Fund.

 

3.     A copy of Rider 13 to the Insurance Policy Number 87028208B confirming the addition of the Fund.

 

Please be advised that the premium for the currently effective bond has been paid for the period July 15, 2008 through July 15, 2009.

 

Very truly yours,

 

/s/William J. Renahan

 

William J. Renahan

 

Assistant Secretary

 

 



 

Amendment to Schedule I

 

This Schedule I dated April 6, 2009, supercedes and amends, the Schedule I which is presently part of the Agreement Concerning Allocation of Fidelity Bond Premiums and Recoveries dated as of September 12, 2008 and The Individual Mutual Funds listed on Schedule I (the “Funds”).

 

Barrett Opportunity Fund Inc.

 

Legg Mason Partners Equity Trust

Legg Mason Partners Financial Services Fund

LMP Global Equity Fund

LMP Diversified Large Cap Growth Fund

LMP 130/30 US Large Cap Equity Fund

LMP Capital and Income Fund

LMP Fundamental Value Fund

LMP Lifestyle Allocation 30%

LMP Lifestyle Allocation 50%

LMP Lifestyle Income Fund

LMP Lifestyle Allocation 85%

LMP Lifestyle Allocation 70%

LMP Large Cap Growth Fund

LMP Aggressive Growth Fund

LMP Lifestyle Allocation 100%

LMP All Cap Fund

LMP Mid Cap Core Fund

LMP Small Cap Core Fund

LMP S&P 500 Index Fund

LMP Capital Fund, Inc.

LMP Investors Value Fund, Inc.

LMP Small Cap Growth Fund

LMP Convertible Fund

LMP Appreciation Fund

LMP Social Awareness Fund

LMP International All Cap Opportunity Fd

LMP Equity Fund

Legg Mason Partners U.S. Large Cap Equity Fund

LMP Emerging Markets Equity Fund

LMP Small Cap Value Fund

LMP Dividend Strategy Fund

LMP Target Retirement 2015

LMP Target Retirement 2020

LMP Target Retirement 2025

LMP Target Retirement 2030

LMP Target Retirement 2035

LMP Target Retirement 2040

LMP Target Retirement 2045

LMP Target Retirement 2050

LMP Target Date Retirement Fund

LMP Equity Income Builder Fund

Legg Mason Permal Allocation Fund

 



 

Legg Mason Partners Income Trust

LMP Global Income Fund

LMP Strategic Income Fund

LMP Government Securities Fund

LMP Pennsylvania Municipals Fund

LMP Oregon Municipals Fund

LMP Intermediate Maturity NY Municipals Fund

LMP New York Municipals Fund

LMP California Municipals Fund

LMP Core Bond Fund

LMP Managed Municipals Fund

LMP Intermediate Maturity CA Municipals Fund

LMP Municipal High Income Fund

LMP Massachusetts Municipals Fund

LMP New Jersey Municipals Fund

LMP Intermediate-Term Municipals Fund

LMP High Income Fund

LMP Corporate Bond Fund

LMP Core Plus Bond Fund

LMP Short Term Bond Fund

LMP Adjustable Rate Income Fund

LMP Global Inflation Management Fund

Western Asset Global High Yield Debt Portfolio

Western Asset Emerging Markets Debt Portfolio

LMP Global High Yield Bond Fund

LMP Short Duration Muni Income Fund

 

Legg Mason Partners Institutional Trust

Citi Institutional Liquid Reserves

Citi Institutional U.S. Treasury Reserves

Citi Institutional Cash Reserves

Citi Institutional Tax Free Reserves

Citi Institutional Enhanced Income Fund

SMASh Series M Portfolio

SMASh Series C Portfolio

SMASh Series EC Portfolio

Western Asset Institutional Money Market Fund

Western Asset Institutional Govt Money Market Fund

Western Asset Institutional Municipal Money Market Fund

 

Legg Mason Partners Money Market Trust

Citi California Tax Free Reserves

Citi Cash Reserves

Citi Tax Free Reserves

Citi New York Tax Free Reserves

Citi U.S. Treasury Reserves

Citi Connecticut Tax Free Reserves

Western Asset Massachusetts Money Market Fund

Western Asset Municipal Money Market Fund

Western Asset New York Municipal Money Market

Western Asset California Municipal Money Market

Western Asset Money Market Fund

Western Asset Government Money Market Fund

 



 

WA AMT Tax Free Money Market Fund

 

Legg Mason Partners Premium Money Market Trust

Citi Liquid Reserves Hub

Citi Premium Liquid Reserves

Citi Premium U.S. Treasury Reserves

 

Legg Mason Partners Variable Equity Trust

LMP Variable Global Equity Portfolio

LMP Variable Capital and Income Portfolio

LMP Variable Lifestyle Allocation 50%

LMP Variable Aggressive Growth Portfolio

LMP Variable International All Cap Opportunity Portfolio

LMP Variable Appreciation Portfolio

LMP Variable Lifestyle Allocation 85%

LMP Variable Lifestyle Allocation 70%

LMP Variable Dividend Strategy Portfolio

LMP Variable Large Cap Growth Portfolio

LMP Variable Mid Cap Core Portfolio

LMP Variable Equity Index Portfolio

LMP Variable Social Awareness Portfolio

LMP Variable Investors Portfolio

LMP Variable Small Cap Growth Portfolio

LMP Variable Fundamental Value Portfolio

LMP Variable Capital Portfolio

 

Legg Mason Partners Variable Income Trust

LMP Variable Diversified Strategic Inc Portfolio

LMP Variable Money Market Portfolio

LMP Variable High Income Portfolio

LMP Variable Strategic Bond Portfolio

LMP Variable Global High Yield Bond Portfolio

LMP Variable Adjustable Rate Income Portfolio

 

LMP Capital and Income Fund Inc.

 

LMP Corporate Loan Fund Inc.

 

LMP Real Estate Income Fund Inc.

 

Master Portfolio Trust

Tax Free Reserves Portfolio

U.S. Treasury Reserves Portfolio

Prime Cash Reserves Portfolio

Institutional Enhanced Portfolio

SMASh Series M Portfolio Hub

SMASh Series C Portfolio Hub

SMASh Series EC Portfolio Hub

 

Western Asset Emerging Markets Debt Fund Inc.

 



 

Western Asset Emerging Markets Floating Rate Fund Inc.

 

Western Asset Emerging Markets Income Fund II Inc.

 

Western Asset Global High Income Fund Inc.

 

Western Asset Global Partners Income Fund Inc.

 

Western Asset High Income Fund II Inc.

 

Western Asset High Income Fund Inc.

 

Western Asset High Income Opportunity Fund Inc.

 

Western Asset Inflation Management Fund Inc.

 

Western Asset Intermediate Muni Fund Inc.

 

Western Asset Managed High Income Fund Inc.

 

Western Asset Managed Municipals Fund Inc.

 

Western Asset Municipal High Income Fund Inc.

 

Western Asset Municipal Partners Fund Inc.

 

Western Asset Variable Rate Strategic Fund Inc.

 

Western Asset Worldwide Income Fund Inc.

 

Legg Mason Permal Global Active Strategies Master Fund

 

Legg Mason Permal Global Active Strategies Fund

 

Legg Mason Permal Global Active Strategies TEI Fund

 

Western Asset Institutional Government Money Market Fund

 

Western Asset Municipal Defined Opportunity Trust Inc.

 



 

 

 

The Individual Mutual Funds listed on Schedule I hereto, which may be amended from time to time in accordance with the terms hereof, each of which is acting in its own capacity and not on behalf of any other entity,

 

 

 

 

 

 

 

By:

 

/s/ R. Jay Gerken

 

 

 

 

 

 

 

Name:

 

R.J. Gerken

 

 

 

 

 

 

 

Title:

 

Chairman,President & CEO

 

 

 

 

 

 

 

Date:

 

April 6, 2009

 

 

 

 

 

 

 

Consented and agreed to:

 

 

 

 

 

 

 

With respect to Barrett Opportunity Fund, Inc.:

 

 

 

 

 

 

 

By:

 

/s/ Peter. H. Shriver

 

 

 

 

 

 

 

Name:

 

Peter H. Shriver

 

 

 

 

 

 

 

Title:

 

President & CEO

 

 

 

 

 

 

 

Date:

 

April 6, 2009

 



 

RESOLVED:

 

That the appropriate officers of the Fund be, and each hereby is, authorized and directed to take and/or ratify all necessary action for the Fund to become a member of ICI Mutual Insurance Company (“ICI Mutual”) and, in conjunction with other investment companies for which affiliates of LMPFA serve as investment adviser and/or administrator, to purchase from ICI Mutual fidelity bond coverage (“Joint Fidelity Bond”) and a Directors and Officers/Errors and Omissions (“D&O/E&O”) liability insurance policy to which the investment adviser, sub-adviser, principal underwriter, administrator, directors and/or officers of such investment companies may also be parties; and further

 

 

 

RESOLVED:

 

That it is the finding of the Board that the Joint Fidelity Bond covering, among others, officers and employees of the Fund in accordance with the requirements of Rule 17g-1 under the 1940 Act is reasonable in form and amount, after having given due consideration to, among other things, the value of the aggregate assets of the Fund to which any person covered under the Joint Fidelity Bond may have access, the type and terms of the arrangements made for the custody and safekeeping of the Fund’s assets and the nature of the securities in the Fund’s portfolio; and further

 

 

 

RESOLVED:

 

That the portion of the total premium for the Joint Fidelity Bond to be allocated to the Fund based on its net assets (following the public offering of its Common Stock) be, and hereby is, approved by a vote of a majority of the Board of Directors of the Fund (all Directors voting) and separately by a majority of the “non-interested” Directors, after having given due consideration to, among other things, the number of the other parties named as insureds, the nature of the business activities of such other parties, the amount of the Joint Fidelity Bond, the amount of the premiums for the Fidelity Bond, the ratable allocation of the premiums among all parties named as insureds, and the extent to which the share of the premium allocated to the Fund is less than the premium the Fund would have had to pay if it had provided and maintained a fidelity bond which covers only the Fund as the insured; and further

 

 

 

RESOLVED:

 

That the Joint Fidelity Bond be, and hereby is, approved by a vote of the Board of Directors (all Directors voting) and separately by the “non-interested” Directors; and further

 

 



 

RESOLVED:

 

That the officers of the Fund be, and each of them hereby is, authorized and directed to enter into an agreement, in substantially the form used for the Closed-end Funds, as required by paragraph (f) of Rule 17g-1 under the 1940 Act with the other named insureds under the Joint Fidelity Bond providing that in the event any recovery is received under the Bond as a result of a loss sustained by the Fund and also by one or more of the other named insureds, the Fund shall receive an equitable and proportionate share of the recovery, but in no event less than the amount it would have received had it obtained and maintained a single insured bond with the minimum coverage required by paragraph (d) (1) of such Rule 17g-1; and further

 

 

 

RESOLVED:

 

That the appropriate officers of the Fund be, and each of them hereby is, authorized and directed to prepare, execute and file such amendments and supplements to the aforesaid agreement, and to take such other action as may be necessary or appropriate in order to conform to the provisions of the 1940 Act and the rules and regulations thereunder; and further

 

 

 

RESOLVED:

 

That the Secretary of the Fund shall file the Joint Fidelity Bond with the Securities and Exchange Commission and give the notices required under paragraph (g) of Rule 17g-1 under the 1940 Act.

 

 



 

ICI MUTUAL INSURANCE COMPANY,

a Risk Retention Group

 

INVESTMENT COMPANY BLANKET BOND

 

RIDER NO. 13

 

INSURED

 

POLICY NUMBER

 

 

 

 

 

Legg Mason Partners Equity Trust

 

87028208B

 

 

EFFECTIVE DATE

 

POLICY PERIOD

 

AUTHORIZED REPRESENTATIVE

 

 

 

 

 

 

 

 

 

July 15, 2008 to July 15, 2009

 

/S/ Matthew Link

 

 

In consideration of the premium charged for this policy, it is hereby understood and agreed that Item 1 of the Declarations, Named Insured Company, shall include the following as of the effective date indicated:

 

FUND NAME

 

EFFECTIVE DATE

 

Western Asset Institutional Government Money Market Fund

 

February 27, 2009

 

Western Asset Municipal Defined Opportunity Trust Inc.

 

March 31, 2009

 

 

Nothing herein contained shall be held to vary, alter, waive or extend any of the terms, conditions, provisions, agreements or limitations of this policy other than as above stated.

 

RN1.1-00 (1/02)