0001193125-20-102562.txt : 20200709 0001193125-20-102562.hdr.sgml : 20200709 20200409160304 ACCESSION NUMBER: 0001193125-20-102562 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20200409 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BrandywineGLOBAL-Global Income Opportunities Fund Inc CENTRAL INDEX KEY: 0001504545 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: (888) 777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Legg Mason BW Global Income Opportunities Fund Inc. DATE OF NAME CHANGE: 20101028 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS MONEY MARKET TRUST CENTRAL INDEX KEY: 0000747576 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: CITIFUNDS TRUST III DATE OF NAME CHANGE: 19981030 FORMER COMPANY: FORMER CONFORMED NAME: LANDMARK CASH RESERVES DATE OF NAME CHANGE: 19910320 FORMER COMPANY: FORMER CONFORMED NAME: LANDMARK FUNDS CASH RESERVES INC DATE OF NAME CHANGE: 19861030 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS INCOME TRUST CENTRAL INDEX KEY: 0000764624 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: LEGG MASON PARTNERS INCOME FUNDS DATE OF NAME CHANGE: 20060407 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY INCOME FUNDS DATE OF NAME CHANGE: 19941228 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY SHEARSON INCOME FUNDS DATE OF NAME CHANGE: 19931015 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS PREMIUM MONEY MARKET TRUST CENTRAL INDEX KEY: 0000850628 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: CITIFUNDS PREMIUM TRUST DATE OF NAME CHANGE: 20051108 FORMER COMPANY: FORMER CONFORMED NAME: CITIFUNDS PREMIUM TRST DATE OF NAME CHANGE: 19981030 FORMER COMPANY: FORMER CONFORMED NAME: LANDMARK INSTITUTIONAL CASH RESERVES DATE OF NAME CHANGE: 19900102 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS VARIABLE INCOME TRUST CENTRAL INDEX KEY: 0000874835 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: LEGG MASON PARTNERS VARIABLE PORTFOLIOS II DATE OF NAME CHANGE: 20060501 FORMER COMPANY: FORMER CONFORMED NAME: GREENWICH STREET SERIES FUND DATE OF NAME CHANGE: 19970902 FORMER COMPANY: FORMER CONFORMED NAME: SHEARSON SERIES FUND DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS EQUITY TRUST CENTRAL INDEX KEY: 0000880366 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: LEGG MASON PARTNERS INVESTMENT TRUST DATE OF NAME CHANGE: 20060407 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY INVESTMENT TRUST DATE OF NAME CHANGE: 19950831 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY SHEARSON INCOME TRUST DATE OF NAME CHANGE: 19931213 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS INSTITUTIONAL TRUST CENTRAL INDEX KEY: 0000889512 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: CITIFUNDS INSTITUTIONAL TRUST DATE OF NAME CHANGE: 19981030 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MASTER PORTFOLIO TRUST CENTRAL INDEX KEY: 0001140869 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: INSTITUTIONAL PORTFOLIO DATE OF NAME CHANGE: 20010518 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LEGG MASON PARTNERS VARIABLE EQUITY TRUST CENTRAL INDEX KEY: 0001176343 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 1-877-721-1926 MAIL ADDRESS: STREET 1: LEGG MASON & CO., LLC STREET 2: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Legg Mason Partners Variable Portfolios IV DATE OF NAME CHANGE: 20060501 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY MULTIPLE DISCIPLINE TRUST DATE OF NAME CHANGE: 20021004 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY MULTIPLE DISCIPLINE ACCOUNT TRUST DATE OF NAME CHANGE: 20020626 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Legg Mason ETF Investment Trust CENTRAL INDEX KEY: 0001645194 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 877-721-1926 MAIL ADDRESS: STREET 1: 620 EIGHTH AVE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Legg Mason ETF InvestmentTrust DATE OF NAME CHANGE: 20170221 FORMER COMPANY: FORMER CONFORMED NAME: Legg Mason ETF Equity Trust DATE OF NAME CHANGE: 20150615 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset High Yield Defined Opportunity Fund Inc. CENTRAL INDEX KEY: 0001497186 IRS NUMBER: 273075810 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 55 WATER STREET CITY: NEW YORK STATE: NY ZIP: 10041 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 55 WATER STREET CITY: NEW YORK STATE: NY ZIP: 10041 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET INTERMEDIATE MUNI FUND INC. CENTRAL INDEX KEY: 0000882300 IRS NUMBER: 133643581 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: INTERMEDIATE MUNI FUND INC DATE OF NAME CHANGE: 20020219 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY INTERMEDIATE MUNICIPAL FUND INC DATE OF NAME CHANGE: 19920909 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY INTERMEDIATE QUALITY MUNICIPAL FUND INC DATE OF NAME CHANGE: 19600201 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET MANAGED MUNICIPALS FUND INC. CENTRAL INDEX KEY: 0000886043 IRS NUMBER: 000000000 FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: MANAGED MUNICIPALS PORTFOLIO INC DATE OF NAME CHANGE: 19920929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET MUNICIPAL PARTNERS FUND INC. CENTRAL INDEX KEY: 0000894351 IRS NUMBER: 133694722 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: WETERN ASSET MUNICIPAL PARTNERS FUND INC. DATE OF NAME CHANGE: 20061010 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS MUNICIPAL PARTNERS FUND INC DATE OF NAME CHANGE: 20030505 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL PARTNERS FUND INC DATE OF NAME CHANGE: 19930714 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET VARIABLE RATE STRATEGIC FUND INC. CENTRAL INDEX KEY: 0001299393 IRS NUMBER: 510522808 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Salomon Brothers Variable Rate Strategic Fund Inc. DATE OF NAME CHANGE: 20040903 FORMER COMPANY: FORMER CONFORMED NAME: Salomon Brothers Floating Rate Strategic Fund Inc. DATE OF NAME CHANGE: 20040803 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Clarion Partners Real Estate Income Fund Inc. CENTRAL INDEX KEY: 0001762562 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 8TH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 8887770102 MAIL ADDRESS: STREET 1: 620 8TH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET FUNDS INC CENTRAL INDEX KEY: 0000863520 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 INTERNATIONAL DRIVE CITY: BALTIMORE STATE: MD ZIP: 21202 BUSINESS PHONE: 410-454-2760 MAIL ADDRESS: STREET 1: 100 INTERNATIONAL DRIVE STREET 2: 7TH FLOOR CITY: BALTIMORE STATE: MD ZIP: 21202 FORMER COMPANY: FORMER CONFORMED NAME: LM INSTITUTIONAL FUND ADVISORS I INC DATE OF NAME CHANGE: 19980818 FORMER COMPANY: FORMER CONFORMED NAME: WESTERN ASSET TRUST INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET PREMIER BOND FUND CENTRAL INDEX KEY: 0001163792 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 385 EAST COLORADO BLVD CITY: PASADENA STATE: CA ZIP: 91101 BUSINESS PHONE: (626) 844-9400 MAIL ADDRESS: STREET 1: 385 EAST COLORADO BLVD CITY: PASADENA STATE: CA ZIP: 91101 FORMER COMPANY: FORMER CONFORMED NAME: WESTERN ASSET CORE PLUS BOND TRUST I DATE OF NAME CHANGE: 20011218 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Legg Mason Global Asset Management Trust CENTRAL INDEX KEY: 0001474103 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 INTERNATIONAL DRIVE CITY: BALTIMORE STATE: MD ZIP: 21202 BUSINESS PHONE: 410-539-0000 MAIL ADDRESS: STREET 1: 100 INTERNATIONAL DRIVE CITY: BALTIMORE STATE: MD ZIP: 21202 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset Investment Grade Income Fund Inc. CENTRAL INDEX KEY: 0000075398 IRS NUMBER: 952808650 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 INTERNATIONAL DRIVE CITY: BALTIMORE STATE: MD ZIP: 21202 BUSINESS PHONE: 4105390000 MAIL ADDRESS: STREET 1: 100 INTERNATIONAL DRIVE CITY: BALTIMORE STATE: MD ZIP: 21202 FORMER COMPANY: FORMER CONFORMED NAME: Western Asset Income Fund DATE OF NAME CHANGE: 20050629 FORMER COMPANY: FORMER CONFORMED NAME: PACIFIC AMERICAN INCOME SHARES INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ClearBridge MLP & Midstream Fund Inc. CENTRAL INDEX KEY: 0001488775 IRS NUMBER: 272282398 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: (888) 777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: ClearBridge Energy MLP Fund Inc. DATE OF NAME CHANGE: 20100407 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ClearBridge MLP & Midstream Total Return Fund Inc. CENTRAL INDEX KEY: 0001547341 IRS NUMBER: 454960969 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 800-805-6035 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: ClearBridge Energy MLP Total Return Fund Inc. DATE OF NAME CHANGE: 20120412 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET CORPORATE LOAN FUND INC. CENTRAL INDEX KEY: 0001068963 IRS NUMBER: 521568099 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: LMP CORPORATE LOAN FUND INC. DATE OF NAME CHANGE: 20061010 FORMER COMPANY: FORMER CONFORMED NAME: CITIGROUP INVESTMENTS CORPORATE LOAN FUND INC. DATE OF NAME CHANGE: 20050421 FORMER COMPANY: FORMER CONFORMED NAME: TRAVELERS CORP LOAN FUND INC DATE OF NAME CHANGE: 19980826 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ClearBridge Energy Midstream Opportunity Fund Inc. CENTRAL INDEX KEY: 0001517518 IRS NUMBER: 451474578 STATE OF INCORPORATION: MD FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: ClearBridge Energy MLP Opportunity Fund Inc. DATE OF NAME CHANGE: 20110406 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset Middle Market Debt Fund Inc. CENTRAL INDEX KEY: 0001555085 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset Middle Market Income Fund Inc. CENTRAL INDEX KEY: 0001525355 IRS NUMBER: 452641964 FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: (888) 777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE, 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Western Asset Middle Market & High Yield Fund Inc. DATE OF NAME CHANGE: 20110913 FORMER COMPANY: FORMER CONFORMED NAME: Western Asset Middle Market Income Fund Inc. DATE OF NAME CHANGE: 20110711 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LMP CAPITAL & INCOME FUND INC. CENTRAL INDEX KEY: 0001270131 IRS NUMBER: 470936930 FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O LEGG MASON & CO. LLC STREET 2: 620 EIGHTH AVE., 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 212-805-6024 MAIL ADDRESS: STREET 1: C/O LEGG MASON & CO. LLC STREET 2: 620 EIGHTH AVE., 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS CAPITAL & INCOME FUND INC DATE OF NAME CHANGE: 20031219 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS EQUITY & INCOME FUND INC DATE OF NAME CHANGE: 20031113 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset Mortgage Opportunity Fund Inc. CENTRAL INDEX KEY: 0001478102 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: (888) 777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Western Asset Mortgage Defined Opportunity Fund Inc. DATE OF NAME CHANGE: 20091204 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset Municipal Defined Opportunity Trust Inc. CENTRAL INDEX KEY: 0001454021 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888 - 777 - 0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Western Asset Municipal Term Trust Inc. DATE OF NAME CHANGE: 20090114 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET MUNICIPAL HIGH INCOME FUND INC. CENTRAL INDEX KEY: 0000830487 IRS NUMBER: 000000000 FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL HIGH INCOME FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: SPECIAL OPPORTUNITIES MUNICIPAL FUND INC DATE OF NAME CHANGE: 19881025 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Western Asset Investment Grade Defined Opportunity Trust Inc. CENTRAL INDEX KEY: 0001462586 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET HIGH INCOME OPPORTUNITY FUND INC. CENTRAL INDEX KEY: 0000910068 IRS NUMBER: 133735236 STATE OF INCORPORATION: MD FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: HIGH INCOME OPPORTUNITY FUND INC DATE OF NAME CHANGE: 19941230 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY HIGH INCOME OPPORTUNITY FUND INC DATE OF NAME CHANGE: 19930913 FORMER COMPANY: FORMER CONFORMED NAME: SMITH BARNEY HIGH INCOME FUND INC DATE OF NAME CHANGE: 19930802 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET HIGH INCOME FUND II INC. CENTRAL INDEX KEY: 0001058239 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 8887770102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS HIGH INCOME FUND II INC DATE OF NAME CHANGE: 19980421 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS HIGH YIELD BOND FUND IN DATE OF NAME CHANGE: 19980319 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET GLOBAL CORPORATE DEFINED OPPORTUNITY FUND INC. CENTRAL INDEX KEY: 0001472341 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 888-777-0102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: Western Asset Global Credit Defined Opportunity Fund Inc. DATE OF NAME CHANGE: 20090916 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET GLOBAL HIGH INCOME FUND INC. CENTRAL INDEX KEY: 0001228509 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 8887770102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS GLOBAL HIGH INCOME FUND INC DATE OF NAME CHANGE: 20030617 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS GLOBAL HIGH YIELD FUND INC DATE OF NAME CHANGE: 20030422 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WESTERN ASSET EMERGING MARKETS DEBT FUND INC. CENTRAL INDEX KEY: 0001227862 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 8887770102 MAIL ADDRESS: STREET 1: 620 EIGHTH AVENUE STREET 2: 49TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS EMERGING MARKETS DEBT FUND INC DATE OF NAME CHANGE: 20031003 FORMER COMPANY: FORMER CONFORMED NAME: SALOMON BROTHERS FIXED INCOME STRATEGIC FUND INC DATE OF NAME CHANGE: 20030417 CORRESP 1 filename1.htm SEC Response Letter

Morgan, Lewis & Bockius LLP

One Federal Street

Boston, MA 02110

April 9, 2020

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

 

  Re:

Legg Mason-Sponsored Funds Preliminary Proxy Statements

Ladies and Gentlemen:

On behalf of each of the registrants in the Legg Mason-Sponsored Funds fund complex listed on Appendix A attached hereto (each, a “Registrant”), we enclose herewith pursuant to Rule 20a-1 under the Investment Company Act of 1940, as amended, and Rule 14a-6(h) under the Securities Exchange Act of 1934, as amended (the “1934 Act”), a revised preliminary copy of each of the letter to shareholders, notice of special meeting, joint proxy statement and form of proxy card to be used in connection with the special meeting of shareholders of each Registrant, marked to show changes from the preliminary proxy statement filed by each Registrant on March 25, 2020.

The purpose of the meetings to which the enclosed materials relate is to solicit shareholder approval of the following proposals: (i) to approve a new management agreement; and (ii) to approve new subadvisory agreement(s).

Pursuant to Rule 14a-6(d) under the 1934 Act, definitive copies of the enclosed materials are intended to be released to shareholders on or about April 14, 2020. Accordingly, as discussed with Mr. David Orlic of the Staff of the Division of Investment Management of the Securities and Exchange Commission (the “Commission”), we would appreciate it if the Staff would please confirm as soon as possible that the Registrants may release such definitive materials to shareholders.

As discussed with Mr. Orlic, the registrants in the Legg Mason-Sponsored Funds fund complex listed in Appendix B attached hereto confirm that they will file definitive proxy statements that contain disclosure that, except for matters specific to a Registrant, series of a Registrant (a “Fund”), and/or Board, is substantially similar to the disclosure contained in the revised preliminary proxy statement filed herewith.

This letter also responds to comments we received from Mr. Orlic regarding the preliminary proxy statement filed by each Registrant on March 25, 2020. Following are the Staff’s comments with respect to the preliminary proxy statements and the Registrants’ responses thereto:

 

1.    Comment:    The Staff noted that Saba Capital Management, L.P. filed a preliminary proxy statement in opposition to the proposals in the preliminary proxy statement filed by Western Asset Global High Income Fund Inc. The Staff requested that the Registrant advise the Staff how that will be addressed in the Fund’s proxy statement.

 

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   Response:    The Registrants acknowledge that a preliminary proxy statement has been filed in opposition to the proposals in Western Asset Global High Income Fund Inc.’s preliminary proxy statement. The Registrants also are aware that another proxy statement has been filed by another shareholder. The Registrants have added disclosure noting that certain parties have indicated their opposition to the proposals to approve new management and subadvisory agreements with respect to certain funds, that shareholders may receive solicitation materials, including proxy statements and proxy cards from such other parties, that the Funds request that shareholders not sign or return or vote on any color proxy cards other than a white proxy card provided with the Funds’ proxy statement, that even if a shareholder votes for the proposals on a color proxy card, the holder of the color proxy card may seek to prevent a shareholder’s shares from being counted as present and voted at the meeting, and that the Funds request that shareholders only vote the white proxy card to ensure their vote is counted.
2.    Comment:    The Staff noted that that disclosure in each proxy statement under Board Evaluation states that the disclosure was provided in preliminary draft form and will be superseded by definitive proxy materials to be filed at a later date. The Staff requested that the Registrants file a revised preliminary proxy statement that includes definitive Board Evaluation disclosure.
   Response:    A revised preliminary proxy statement for the Registrants that includes definitive Board Evaluation disclosure is filed herewith. As noted above, the registrants in the Legg Mason-Sponsored Funds fund complex listed in Appendix B attached hereto confirm that they will file definitive proxy statements that contain disclosure that, except for matters specific to a Fund and/or Board, is substantially similar to the disclosure contained in the revised preliminary proxy statement filed herewith.
3.    Comment:    The Staff requested that the revised preliminary proxy statements and revised forms of proxy card be marked to show changes from the initial preliminary materials, in accordance with Rule 14a-6(h).
   Response:    A revised preliminary proxy statement and a revised form of proxy card, each marked to show changes from the initial preliminary materials, are attached hereto.
4.    Comment:    The Staff requested that the Registrants delete the reference to votes being cast for nominees that was inadvertently included in the form of proxy card included in the preliminary proxy statement filings.
   Response:    The Registrants have deleted the statement referred to by the Staff from the form of proxy card.
5.    Comment:    The Staff requested that the applicable Registrants reconcile the statements on the form of insurance company voting instruction card that (i) if no direction is made, the votes attributable to the voting instruction card will be voted for the proposals, and (ii) shares of the Fund(s) for which no instructions are received will be voted in the same proportion as votes for which instructions are received for the Fund(s).
   Response:    The Registrants have deleted from the form of voting instruction card the statement that shares of the Fund(s) for which no instructions are received will be voted in the same proportion as votes for which instructions are received for the Fund(s).

 

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6.    Comment:    The Staff noted that the Registrants state in each proxy statement that the inspectors of election will treat abstentions and “broker non-votes” as present for purposes of determining a quorum. The Staff noted that the proposals in the proxy statement are non-routine proposals with respect to which a broker does not have discretionary voting power. The Staff noted that under NYSE Rules 450-460, if a beneficial owner does not give its broker voting instructions with respect to which the broker does not have discretionary voting power, the broker may not deliver a proxy to the fund and the shares accordingly will not be present at the meeting. That is, it appears that it will never be the case under these facts that a broker that has not received instructions from the beneficial owner will vote on one proposal but not the other (“broker non-votes”). See NYSE Rule 452.13. Accordingly, the Staff requested that the Registrants remove the reference to broker non-votes in this sentence.
   Response:    The Registrants have removed the reference to broker non-votes in the sentence referred to by the Staff.
7.    Comment:    The Staff noted that in each proxy statement, the Registrants state that “in the event of any inconsistency between this Joint Proxy Statement and the agreements described herein, the agreements will control.” The Staff noted that the Registrants have an obligation to accurately summarize the agreements, and requested that the Registrants eliminate the suggestion that they have not done so.
   Response:    The Registrants have deleted the statement referenced by the Staff.
8.    Comment:    The Staff requested that the Registrants revised the disclosure with respect to Section 15(f) of the 1940 Act to disclose each Board’s determination that there will be no “unfair burden” on the Funds pursuant to Section 15(f).
   Response:    The Registrants note that Section 15(f) does not require that a Board determine that the Transaction would not impose an “unfair burden” on any Fund. Accordingly, the Boards did not make that specific determination. However, the Registrants note that, as indicated in the disclosure, the Boards have not been advised by the Legg Mason or Franklin Templeton of any circumstances arising from the Transaction that might result in the imposition of an “unfair burden” and that Franklin Templeton has advised each Board that Franklin Templeton will not take, nor cause its affiliates to take, any action that would have the effect of causing the conditions of Section 15(f) not to be met with respect to the Transaction. The Registrants respectfully submit that no change to the disclosure is required.
9.    Comment:    The Staff requested that the Registrants confirm that the disclosure in each proxy statement with respect to information regarding other funds advised by the Managers and Subadvisers contains all of the information required by Item 22(c)(10) of Schedule 14A.
   Response:    Each Registrant confirms that the disclosure in its proxy statement regarding information with respect to other funds advised by the Managers and Subadvisers contains all of the information required by Item 22(c)(10) of Schedule 14A.

Please call the undersigned at (617) 951-8458 with any questions.

 

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Sincerely,

/s/ Jeremy Kantrowitz

Jeremy Kantrowitz

 

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Appendix A

 

BrandywineGLOBAL– Global Income Opportunities Fund Inc.

    (File No. 811-22491)

Clarion Partners Real Estate Income Fund Inc.

    (File No. 811-23408)

ClearBridge Energy Midstream Opportunity Fund Inc.

    (File No. 811-22546)

ClearBridge MLP and Midstream Fund Inc.

    (File No. 811-22405)

ClearBridge MLP and Midstream Total Return Fund Inc.

    (File No. 811-22693)

LMP Capital and Income Fund Inc.

    (File No. 811-21467)

Western Asset Corporate Loan Fund Inc.

    (File No. 811-08985)

Western Asset Emerging Markets Debt Fund Inc.

    (File No. 811-21343)

Western Asset Global Corporate Defined Opportunity Fund Inc.

    (File No. 811-22334)

Western Asset Global High Income Fund Inc.

    (File No. 811-21337)

Western Asset High Income Fund II Inc.

    (File No. 811-08709)

Western Asset High Income Opportunity Fund Inc.

    (File No. 811-07920)

Western Asset High Yield Defined Opportunity Fund Inc.

    (File No. 811-22444)

Western Asset Intermediate Muni Fund Inc.

    (File No. 811-06506)

Western Asset Investment Grade Defined Opportunity Trust Inc.

    (File No. 811-22294)

Western Asset Managed Municipals Fund Inc.

    (File No. 811-06629)

Western Asset Middle Market Debt Fund Inc.

    (File No. 811-22734)

Western Asset Middle Market Income Fund Inc.

    (File No. 811-22582)

Western Asset Mortgage Opportunity Fund Inc.

    (File No. 811-22369)

 

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Western Asset Municipal Defined Opportunity Trust Inc.

    (File No. 811-22265)

Western Asset Municipal High Income Fund Inc.

    (File No. 811-05497)

Western Asset Municipal Partners Fund Inc.

    (File No. 811-07362)

Western Asset Variable Rate Strategic Fund Inc.

    (File No. 811-21609)

 

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Appendix B

 

Legg Mason Global Asset Management Trust

    (File No. 811-22338)

Legg Mason Partners Equity Trust

    (File No. 811-06444)

Legg Mason ETF Investment Trust

    (File No. 811-23096)

Legg Mason Partners Variable Equity Trust

    (File No. 811-21128)

Legg Mason Partners Income Trust

    (File No. 811-04254)

Western Asset Funds, Inc.

    (File No. 811-06110)

Legg Mason Partners Institutional Trust

    (File No. 811-06740)

Legg Mason Partners Money Market Trust

    (File No. 811-04052)

Legg Mason Partners Premium Money Market Trust

    (File No. 811-05812)

Master Portfolio Trust

    (File No. 811-10407)

Legg Mason Partners Variable Income Trust

    (File No. 811-06310)

Western Asset Investment Grade Income Fund Inc.

    (File No. 811-02351)

Western Asset Premier Bond Fund

    (File No. 811-10603)