497 1 d497.htm LEGG MASON PARTNERS EQUITY TRUST LEGG MASON PARTNERS EQUITY TRUST

 

LEGG MASON PARTNERS EQUITY TRUST

SUPPLEMENT DATED MARCH 12, 2010

TO THE PROSPECTUSES AND

STATEMENTS OF ADDITIONAL INFORMATION

OF THE FUNDS LISTED IN

SCHEDULE A

The following information supplements and to the extent inconsistent therewith, supersedes the information contained in each Fund’s Prospectus.

Frequent trading of Fund Shares

Frequent purchases and redemptions of fund shares may interfere with the efficient management of the funds, increase fund transaction costs, and have a negative effect on the funds’ long-term shareholders. For example, in order to handle large flows of cash into and out of a fund, the portfolio managers may need to allocate more assets to cash or other short-term investments or sell securities, rather than maintaining full investment in securities selected to achieve the fund’s investment objective. Frequent trading may cause a fund to sell securities at less favorable prices. Transaction costs, such as brokerage commissions and market spreads, can detract from a fund’s performance. In addition, the return received by long-term shareholders may be reduced when trades by other shareholders are made in an effort to take advantage of certain pricing discrepancies, when, for example, it is believed that a fund’s share price, which is determined at the close of the NYSE on each trading day, does not accurately reflect the value of the fund’s investments. Funds investing in foreign securities have been particularly susceptible to this form of arbitrage, but other funds could also be affected.

Because of the potential harm to funds sold by LMIS (the funds’ distributor) and their long-term shareholders, the Board has approved policies and procedures that are intended to detect and discourage excessive trading and market timing abuses through the use of various surveillance techniques. Under these policies and procedures, a fund may limit additional exchanges or purchases of fund shares by shareholders who are believed by the manager to be engaged in these abusive trading activities in the fund or in other funds sold by LMIS. In the event that an exchange or purchase request is rejected, the shareholder may nonetheless redeem its shares. The intent of the policies and procedures is not to inhibit legitimate strategies, such as asset allocation,


 

dollar cost averaging, or similar activities that may nonetheless result in frequent trading of fund shares.

Under the funds’ policies and procedures, the funds reserve the right to restrict or reject purchases of shares (including exchanges) without prior notice whenever a pattern of excessive trading by a shareholder is detected in funds distributed by LMIS. A committee established by the manager administers the policy. The policy provides that the committee may take action, which may include using its best efforts to restrict a shareholder’s trading privileges in LMIS distributed funds, if that shareholder has engaged in one or more “Round Trips” across all LMIS distributed funds. However, the committee has the discretion to determine that action is not necessary if it is determined that the pattern of trading is not abusive or harmful. In making such a determination, the committee will consider, among other things, the nature of the shareholder’s account, the reason for the frequent trading, the amount of trading and the particular funds in which the trading has occurred. Additionally, the committee has the discretion to make inquiries or to take any action against a shareholder whose trading appears inconsistent with the frequent trading policy, regardless of the number of Round Trips. Examples of the types of actions the committee may take include heightened surveillance of a shareholder account, providing a written warning letter to an account holder, restricting the shareholder from purchasing additional shares in a fund altogether or imposing other restrictions (such as requiring purchase orders to be submitted by mail) that would deter the shareholder from trading frequently in the funds. The committee will generally follow a system of progressive deterrence, although it is not required to do so.

A “Round Trip” is defined as a purchase (including subscriptions and exchanges) into a fund followed by a sale (including redemptions and exchanges) of the same or a similar number of shares out of the fund within 30 days of such purchase. Purchases and sales of a fund’s shares pursuant to an automatic investment plan or similar program for periodic transactions are not considered in determining Round Trips. These policies and procedures do not apply to money market funds sold by LMIS.

The policies apply to any account, whether a direct account or accounts with financial intermediaries such as investment advisers, broker/dealers or retirement plan administrators, commonly called omnibus accounts, where the intermediary holds fund shares for a number of its customers in one account. A fund’s ability to monitor trading in omnibus accounts may, however, be severely limited due to


 

the lack of access to an individual investor’s trading activity when orders are placed through these types of accounts. There may also be operational and technological limitations on the ability of a fund’s service providers to identify or terminate frequent trading activity within the various types of omnibus accounts. LMIS has entered into agreements with intermediaries requiring the intermediaries to, among other things, help identify frequent trading activity and prohibit further purchases or exchanges by a shareholder identified as having engaged in frequent trading.

The funds have also adopted policies and procedures to prevent the selective release of information about the funds’ holdings, as such information may be used for market-timing and similar abusive practices.

The funds’ policies provide for ongoing assessment of the effectiveness of current policies and surveillance tools, and the Board reserves the right to modify these or adopt additional policies and restrictions in the future. Shareholders should be aware, however, that any surveillance techniques currently employed by the funds or other techniques that may be adopted in the future may not be effective, particularly where the trading takes place through certain types of omnibus accounts. Furthermore, a fund may not apply its policies consistently or uniformly, resulting in the risk that some shareholders may be able to engage in frequent trading while others will bear the costs and effects of that trading.

Although the funds will attempt to monitor shareholder transactions for certain patterns of frequent trading activity, there can be no assurance that all such trading activity can be identified, prevented or terminated. Monitoring of shareholder transactions may only occur for shareholder transactions that exceed a certain transaction amount threshold, which may change from time to time. The funds reserve the right to refuse any client or reject any purchase order for shares (including exchanges) for any reason.

Except for the Legg Mason Partners Batterymarch S&P 500 Index Fund, the following information supplements and to the extent inconsistent therewith, supersedes the information contained in the section of each Fund’s Prospectus titled Dividends, distributions and taxes:

Dividends and distributions

The fund generally pays dividends and makes capital gain distributions, if any, typically once or twice a year. The fund may pay additional distributions

 

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and dividends at other times if necessary for the fund to avoid a federal tax. The fund expects distributions to be primarily from capital gains. Unless otherwise directed, capital gain distributions and dividends are reinvested in additional fund shares of the same class you hold. You do not pay a sales charge on reinvested distributions or dividends. Alternatively, you can instruct your Service Agent, Funds Investor Services or Institutional Shareholder Services to have your distributions and/or dividends paid in cash. You can change your choice at any time to be effective as of the next distribution or dividend.

If you own Class A or Class C shares and hold your shares directly with the fund, you may instruct Funds Investor Services to have your distributions and/or dividends invested in Class A or Class C shares, respectively, of another fund sold by the distributor, subject to the following conditions:

 

   

You have a minimum account balance of $10,000

 

   

The fund is available for sale in your state

To change your election to reinvest your dividends and distributions in shares of another fund, you must notify Funds Investor Services or Institutional Shareholder Services at least three days before the next distribution is to be paid.

Please contact your Service Agent, Funds Investor Services or Institutional Shareholder Services to discuss what options are available to you for receiving your dividends and distributions.

The following information supplements and to the extent inconsistent therewith, supersedes the information contained in the section of each Fund’s Prospectus titled Share Price:

Effective April 5, 2010, when the fund holds securities or other assets that are denominated in a foreign currency, the fund will normally use the currency exchange rates as of 4:00 p.m. (Eastern time)

The following information supplements and to the extent inconsistent therewith, supersedes the information contained in each Fund’s Statement of Additional Information:

 

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DISCLOSURE OF PORTFOLIO HOLDINGS

The funds’ Board has adopted policies and procedures developed by the manager with respect to the disclosure of a fund’s portfolio securities and any ongoing arrangements to make available information about the fund’s portfolio securities. The policy requires that consideration always be given as to whether disclosure of information about a fund’s portfolio holdings is in the best interests of the fund’s shareholders. As a consequence, any conflicts of interest between the interests of the fund’s shareholders and those of the manager, the distributor or their affiliates in connection with the disclosure of portfolio holdings information would be addressed in a manner that places the interests of fund shareholders first.

The policy provides that information regarding a fund’s portfolio holdings may be shared with the manager, a fund’s subadvisers and other affiliated parties involved in the management, administration or operations of the fund (referred to as fund-affiliated personnel).

Under the policy, a fund’s complete list of holdings (including the size of each position) may be made available to investors, potential investors, third parties and Legg Mason personnel that are not fund-affiliated personnel: (i) upon the filing of Form N-Q or Form N-CSR in accordance with SEC rules, provided that such filings are not made until 15 calendar days following the end of the period covered by the Form N-Q or Form N-CSR or (ii) no sooner than 15 days after month end, provided that such information has been made available through public disclosure at least one day previously. Typically, public disclosure is achieved by required filings with the SEC and/or posting the information to Legg Mason’s or the funds’ Internet site that is accessible by the public, or through public release by a third party vendor.

The policy also permits the release of limited portfolio holdings information to investors, potential investors, third parties and Legg Mason personnel that are not fund-affiliated personnel in other circumstances, including:

1. A fund’s top ten securities, current as of month-end, and the individual size of each such security position may be released at any time following month-end with simultaneous public disclosure.

 

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2. A fund’s top ten securities positions (including the aggregate but not individual size of such positions) may be released at any time with simultaneous public disclosure.

3. A list of securities (that may include fund holdings together with other securities) followed by a portfolio manager (without position sizes or identification of particular funds) may be disclosed to sell-side brokers at any time for the purpose of obtaining research and/or market information from such brokers.

4. A trade in process may be discussed only with counterparties, potential counterparties and others involved in the transaction (i.e., brokers and custodians).

5. A fund’s sector weightings, yield and duration (for fixed income and money market funds), performance attribution (e.g., analysis of the fund’s out-performance or underperformance of its benchmark based on its portfolio holdings) and other summary and statistical information that does not include identification of specific portfolio holdings may be released, even if non-public, if such release is otherwise in accordance with the policy’s general principles.

6. A small number of a fund’s portfolio holdings (including information that the fund no longer holds a particular holding) may be released, but only if the release of the information could not reasonably be seen to interfere with current or future purchase or sales activities of the fund and is not contrary to law.

7. A fund’s portfolio holdings may be released on an as-needed basis to its legal counsel, counsel to its independent trustees and its independent public accounting firm, in required regulatory filings or otherwise to governmental agencies and authorities.

Under the policy, a fund may release portfolio holdings information on a regular basis to a custodian, sub-custodian, fund accounting agent, proxy voting provider, rating agency or other vendor or service provider for a legitimate business purpose, where the party receiving the information is under a duty of confidentiality, including a duty to prohibit the sharing of non-public information with unauthorized sources and trading upon non-public information. A fund may enter into other ongoing arrangements

 

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for the release of portfolio holdings information for a legitimate business purpose with a party who is subject to a confidentiality agreement and restrictions on trading upon non-public information. None of the funds, Legg Mason or any other affiliated party may receive compensation or any other consideration in connection with such arrangements. Ongoing arrangements to make available information about a fund’s portfolio securities will be reviewed at least annually by the fund’s board.

The approval of the funds’ Chief Compliance Officer, or designee, must be obtained before entering into any new ongoing arrangement or altering any existing ongoing arrangement to make available portfolio holdings information, or with respect to any exceptions from the policy. Any exceptions from the policy must be consistent with the purposes of the policy. Exceptions are considered on a case-by-case basis and are granted only after a thorough examination and consultation with the manager’s legal department, as necessary. Exceptions from the policy are reported annually to each fund’s board.

Generally, the funds disclose their complete portfolio holdings approximately 15 days after month end on Legg Mason’s website: http://www.leggmason.com/individualinvestors.

Set forth below is a list, as of December 31, 2009, of those parties with whom the manager, on behalf of each fund, has authorized ongoing arrangements that include the release of portfolio holdings information in accordance with the policy, as well as the frequency of the release under such arrangements, and the length of the lag, if any, between the date of the information and the date on which the information is disclosed. The parties identified below as recipients are service providers, fund rating agencies, consultants and analysts.

 

Recipient

  

Frequency

  

Delay Before Dissemination

State Street Bank & Trust Co. (Fund Custodian and Accounting Agent)    Daily    None
RiskMetrics Group (formerly Institutional Shareholder Services) (Proxy Voting Services)    As necessary    None
Bloomberg    Quarterly    25 Days after Quarter End
Lipper    Quarterly    25 Days after Quarter End
S&P    Quarterly    25 Days after Quarter End
Morningstar    Quarterly    25 Days after Quarter End
Thomson/Vestek    Daily    None

 

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Recipient

  

Frequency

  

Delay Before Dissemination

Factset    Daily    None
The Bank of New York Mellon    Daily    None
Thomson    Semi-annually    None
SunGard/Protogent (formerly Dataware)    Daily    None
ITG    Daily    None

Portfolio holdings information for the fund may also be released from time to time pursuant to ongoing arrangements with the following parties:

 

Recipient

   Frequency   Delay Before Dissemination
Baseline    Daily   None
Frank Russell    Monthly   1 Day
Callan    Quarterly   25 Days after Quarter End
Mercer    Quarterly   25 Days after Quarter End
eVestment Alliance    Quarterly   25 Days after Quarter End
RogersCasey (equest)    Quarterly   25 Days after Quarter End
Cambridge Associates    Quarterly   25 Days after Quarter End
Marco Consulting    Quarterly   25 Days after Quarter End
Wilshire    Quarterly   25 Days after Quarter End
Informa Investment Services (Efron)    Quarterly   25 Days after Quarter End
CheckFree (Mobius)    Quarterly   25 Days after Quarter End
Nelsons Information    Quarterly   25 Days after Quarter End
Investor Tools    Daily   None
Advent    Daily   None
BARRA    Daily   None
Plexus    Quarterly(Calendar)   Sent 1-3 Business Days
after Quarter End
Elkins/McSherry    Quarterly(Calendar)   Sent 1-3 Business Days
after Quarter End
Quantitative Services Group    Daily   None
AMBAC    Daily   None
Deutsche Bank    Monthly   6-8 Business Days
Fitch    Monthly   6-8 Business Days
Liberty Hampshire    Weekly and Month End   None
SunTrust    Weekly and Month End   None
New England Pension Consultants    Quarterly   25 Days after Quarter End
Evaluation Associates    Quarterly   25 Days after Quarter End
Watson Wyatt    Quarterly   25 Days after Quarter End
S&P (Rating Agency)    Weekly Tuesday Night*   1 Business Day*
Moody’s (Rating Agency)    Monthly*   6-8 Business Days*
Electra Information Systems    Daily   None
Cabot Research    Weekly   None
Goldman Sachs    Daily   None
Chicago Mercantile Exchange    Daily   None
Canterbury Consulting    Quarterly   25 Days after Quarter End

 

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Recipient

   Frequency    Delay Before Dissemination
Broadridge    Daily    None
DST Global Solutions    As necessary    Varies
Interactive Data Corp.    Daily    None
Citigroup Global Markets Inc.    Daily    None
Glass Lewis & Co.    Daily    None
Fidelity    Quarterly    5 Business Days

The funds’ portfolio holdings policy is designed to prevent sharing of portfolio information with third parties who have no legitimate business purpose for accessing the information. The policy may not be effective to limit access to portfolio holdings information in all circumstances, however. For example, a subadviser may manage accounts other than a fund that have investment objectives and strategies similar to those of the fund. Because these accounts may be similarly managed, portfolio holdings may be similar across the accounts. In that case, an investor in another account may be able to infer the portfolio holdings of the fund from the portfolio holdings in the investor’s account.

 

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Schedule A

LEGG MASON PARTNERS EQUITY TRUST

      Date of
Prospectus
Legg Mason Barrett Financial Services Fund    7/29/09
Legg Mason Capital Management All Cap Fund    8/28/09
as amended
11/25/09
Legg Mason ClearBridge Aggressive Growth Fund    12/29/09
Legg Mason ClearBridge Appreciation Fund    2/26/10
Legg Mason ClearBridge Capital Fund    2/26/10
Legg Mason ClearBridge Diversified Large Cap Growth Fund    2/26/10
Legg Mason ClearBridge Dividend Strategy Fund    2/26/10
Legg Mason ClearBridge Equity Fund    4/30/09
Legg Mason ClearBridge Equity Income Builder Fund    4/30/09
Legg Mason ClearBridge Fundamental All Cap Value Fund    1/28/10
Legg Mason Batterymarch Global Equity Fund    2/26/10
Legg Mason Global Currents International All Cap Opportunity Fund    2/26/10
Legg Mason ClearBridge Large Cap Growth Fund    3/19/09
Legg Mason ClearBridge Large Cap Value Fund    2/26/10
Legg Mason Lifestyle Allocation 100%    5/31/09
Legg Mason Lifestyle Allocation 30%    5/31/09
Legg Mason Lifestyle Allocation 50%    5/31/09
Legg Mason Lifestyle Allocation 70%    5/31/09
Legg Mason Lifestyle Allocation 85%    5/31/09
Legg Mason Lifestyle Income Fund    5/31/09
Legg Mason ClearBridge Mid Cap Core Fund    2/26/10
Legg Mason Batterymarch S&P 500 Index Fund    1/28/10
Legg Mason ClearBridge Small Cap Growth Fund    2/26/10
Legg Mason ClearBridge Small Cap Value Fund    1/28/10
Legg Mason Esemplia Emerging Markets Equity Fund    2/26/10
Legg Mason Investment Counsel Social Awareness Fund    5/31/09
Legg Mason Target Retirement 2015    5/31/09
Legg Mason Target Retirement 2020    5/31/09
Legg Mason Target Retirement 2025    5/31/09
Legg Mason Target Retirement 2030    5/31/09
Legg Mason Target Retirement 2035    5/31/09
Legg Mason Target Retirement 2040    5/31/09
Legg Mason Target Retirement 2045    5/31/09
Legg Mason Target Retirement 2050    5/31/09
Legg Mason Target Retirement Fund    5/31/09
Legg Mason Batterymarch U.S. Large Cap Equity Fund    3/30/09
Legg Mason Permal Tactical Allocation Fund    4/13/09

 

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