SEC Company Response from WESTERN ASSET MUNICIPAL HIGH INCOME FUND INC. (MHF) (CIK 0000830487) (MHF) — Oct 1, 2019
WESTERN ASSET MUNICIPAL HIGH INCOME FUND INC. (MHF) (CIK 0000830487)
Date: Oct. 1, 2019 · CIK: 0000830487 · Accession: 0001193125-19-259527
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-02351, 811-04052, 811-04254, 811-05497, 811-05812, 811-06110, 811-06310, 811-06444, 811-06506, 811-06740, 811-07362, 811-07920, 811-10603, 811-21128, 811-21343, 811-21403, 811-21477, 811-21609, 811-22265, 811-22294, 811-22334, 811-22338, 811-22369, 811-22405, 811-22444, 811-22546, 811-22693, 811-22805, 811-23096, 811-23107
Letter
VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Attention: Ken Ellington Re: The Registrants (the “Registrants”) and Fund (the “Funds”) Listed in Annex A
Dear Mr. Ellington:
On August 29, on behalf of the Registrants,1 we filed a letter responding to comments that you delivered by telephone on July 31, 2019 on behalf of the Staff (the “Staff”) of the Securities and Exchange Commission after the Staff’s review of the Funds’ annual reports to shareholders filed on Form N-CSR, in each case with respect to the fiscal year listed beside the name of the applicable Fund in Annex A hereto.
On September 6, 2019, you and Sally Samuel of the Staff reiterated the Staff’s view with respect to certain comments initially delivered on July 31, 2019 – specifically, comment 4 (relating to the Staff’s request that “global” Funds disclose the extent to which they invest their assets in investments that are tied economically to countries other than the United States) and comment 5 (relating to the Staff’s position that, for purposes of their concentration policies, Funds must assign an industry classification to each mortgage-related security or asset-backed security in which they invest).
The purpose of this letter is to confirm to the Staff that the Registrants understand the Staff’s positions with respect to the above-referenced matters and to advise the Staff that the Registrants are currently evaluating such matters.
Please contact the undersigned at 617-951-8267 with any questions or comments you might have regarding the above.
Sincerely,
/s/ Barry N. Hurwitz
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CORRESP 1 filename1.htm LEGG MASON PARTNERS INCOME TRUST Morgan, Lewis & Bockius LLP One Federal Street Boston, MA 02110 October 1, 2019 VIA EDGAR Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Attention: Ken Ellington Re: The Registrants (the “Registrants”) and Fund (the “Funds”) Listed in Annex A Dear Mr. Ellington: On August 29, on behalf of the Registrants,1 we filed a letter responding to comments that you delivered by telephone on July 31, 2019 on behalf of the Staff (the “Staff”) of the Securities and Exchange Commission after the Staff’s review of the Funds’ annual reports to shareholders filed on Form N-CSR, in each case with respect to the fiscal year listed beside the name of the applicable Fund in Annex A hereto. On September 6, 2019, you and Sally Samuel of the Staff reiterated the Staff’s view with respect to certain comments initially delivered on July 31, 2019 – specifically, comment 4 (relating to the Staff’s request that “global” Funds disclose the extent to which they invest their assets in investments that are tied economically to countries other than the United States) and comment 5 (relating to the Staff’s position that, for purposes of their concentration policies, Funds must assign an industry classification to each mortgage-related security or asset-backed security in which they invest). The purpose of this letter is to confirm to the Staff that the Registrants understand the Staff’s positions with respect to the above-referenced matters and to advise the Staff that the Registrants are currently evaluating such matters. Please contact the undersigned at 617-951-8267 with any questions or comments you might have regarding the above. Sincerely, /s/ Barry N. Hurwitz 1 When used in the responses below, term “Fund” refers to the applicable Fund and the term “Registrant” refers to the Registrant listed beside the name of such Fund in Annex A. Annex A Registrant 1940 Act File No. Fund Series Identifier Fiscal Year LEGG MASON PARTNERS INCOME TRUST 811-04254 Western Asset Income Fund S000008972 7/31/2018 Western Asset Municipal High Income Fund S000008976 7/31/2018 Western Asset Short Duration High Income Fund S000008975 7/31/2018 Western Asset Short Term Yield Fund S000032916 7/31/2018 Western Asset Short Duration Municipal Income Fund S000016249 2/28/2019 Western Asset Intermediate Maturity California Municipals Fund S000016650 11/30/2018 Western Asset Intermediate Maturity New York Municipals Fund S000016625 11/30/2018 Western Asset Massachusetts Municipals Fund S000016629 11/30/2018 Western Asset Corporate Bond Fund S000016627 12/31/2018 Western Asset Global High Yield Bond Fund S000016648 12/31/2018 Western Asset Mortgage Backed Securities Fund S000016649 12/31/2018 Western Asset Short-Term Bond Fund S000016639 12/31/2018 LEGG MASON PARTNERS MONEY MARKET TRUST 811-04052 Western Asset Prime Obligations Money Market Fund S000052041 8/31/2018 Western Asset Government Reserves S000016623 8/31/2018 Western Asset New York Tax Free Money Market Fund S000008928 8/31/2018 Western Asset Tax Free Reserves S000008929 8/31/2018 Western Asset U.S. Treasury Reserves S000008930 8/31/2018 LEGG MASON PARTNERS PREMIUM MONEY MARKET TRUST 811-05812 Western Asset Premium Liquid Reserves S000008923 8/31/2018 Western Asset Premium U.S. Treasury Reserves S000008924 8/31/2018 LEGG MASON PARTNERS VARIABLE EQUITY TRUST 811-21128 ClearBridge Variable Aggressive Growth Portfolio S000016933 12/31/2018 ClearBridge Variable Appreciation Portfolio S000017013 12/31/2018 ClearBridge Variable Dividend Strategy Portfolio S000008304 12/31/2018 ClearBridge Variable Large Cap Growth Portfolio S000016935 12/31/2018 ClearBridge Variable Large Cap Value Portfolio S000017019 12/31/2018 ClearBridge Variable Mid Cap Portfolio S000016937 12/31/2018 ClearBridge Variable Small Cap Growth Portfolio S000017007 12/31/2018 QS Legg Mason Dynamic Multi-Strategy VIT Portfolio S000034620 12/31/2018 QS Variable Conservative Growth S000017009 12/31/2018 QS Variable Growth S000017011 12/31/2018 QS Variable Moderate Growth S000017010 12/31/2018 LEGG MASON PARTNERS VARIABLE INCOME TRUST 811-06310 Western Asset Core Plus VIT Portfolio S000016930 12/31/2018 Western Asset Variable Global High Yield Bond Portfolio S000017004 12/31/2018 WESTERN ASSET EMERGING MARKETS DEBT FUND INC. 811-21343 Western Asset Emerging Markets Debt Fund Inc. CEF0000891 12/31/2018 WESTERN ASSET FUNDS INC. 811-06110 Western Asset Macro Opportunities Fund S000041845 10/31/2018 Western Asset Core Bond Fund S000000713 12/31/2018 Western Asset Core Plus Bond Fund S000000714 12/31/2018 Western Asset Inflation Indexed Plus Bond Fund S000000715 12/31/2018 WESTERN ASSET HIGH YIELD DEFINED OPPORTUNITY FUND INC. 811-22444 Western Asset High Yield Defined Opportunity Fund Inc. CEF0001407 8/31/2018 WESTERN ASSET HIGH INCOME OPPORTUNITY FUND INC. 811-07920 Western Asset High Income Opportunity Fund Inc. CEF0000463 9/30/2018 WESTERN ASSET VARIABLE RATE STRATEGIC FUND INC. 811-21609 Western Asset Variable Rate Strategic Fund Inc. CEF0001014 9/30/2018 WESTERN ASSET GLOBAL CORPORATE DEFINED OPPORTUNITY FUND INC. 811-22334 Western Asset Global Corporate Defined Opportunity Fund Inc. CEF0001347 10/31/2018 WESTERN ASSET MUNICIPAL HIGH INCOME FUND INC. 811-05497 Western Asset Municipal High Income Fund Inc. CEF0000134 10/31/2018 WESTERN ASSET INTERMEDIATE MUNI FUND INC. 811-06506 Western Asset Intermediate Muni Fund Inc. CEF0000302 11/30/2018 WESTERN ASSET INVESTMENT GRADE DEFINED OPPORTUNITY TRUST INC. 811-22294 Western Asset Investment Grade Defined Opportunity Trust Inc. CEF0001329 11/30/2018 WESTERN ASSET MUNICIPAL DEFINED OPPORTUNITY TRUST INC. 811-22265 Western Asset Municipal Defined Opportunity Trust Inc. CEF0001309 11/30/2018 WESTERN ASSET MUNICIPAL PARTNERS FUND INC. 811-07362 Western Asset Municipal Partners Fund Inc. CEF0000388 11/30/2018 WESTERN ASSET INFLATION-LINKED INCOME FUND 811-21403 Western Asset Inflation-Linked Income Fund CEF0000929 11/30/2018 WESTERN ASSET INFLATION-LINKED OPPORTUNITIES & INCOME FUND 811-21477 Western Asset Inflation-Linked Opportunities & Income Fund CEF0000953 11/30/2018 WESTERN ASSET INVESTMENT GRADE INCOME FUND INC. 811-02351 Western Asset Investment Grade Income Fund Inc. CEF0000022 12/31/2018 WESTERN ASSET MORTGAGE DEFINED OPPORTUNITY FUND INC. 811-22369 Western Asset Mortgage Defined Opportunity Fund Inc. CEF0001363 12/31/2018 WESTERN ASSET PREMIER BOND FUND 811-10603 Western Asset Premier Bond Fund CEF0000741 12/31/2018 CLEARBRIDGE AMERICAN ENERGY MLP FUND INC. 811-22805 Clearbridge American Energy MLP Fund Inc. Liquidated ClearBridge MLP & Midstream Fund Inc. 811-22405 ClearBridge MLP & Midstream Fund Inc. 11/30/2018 ClearBridge Energy Midstream Opportunity Fund Inc. 811-22546 ClearBridge Energy Midstream Opportunity Fund Inc. 11/30/2018 ClearBridge MLP & Midstream Total Return Fund Inc. 811-22693 ClearBridge MLP & Midstream Total Return Fund Inc. 11/30/2018 LEGG MASON ETF INVESTMENT TRUST 811-23096 Legg Mason Developed ex-US Diversified Core ETF S000051683 Liquidated Legg Mason Emerging Markets Diversified Core ETF S000051684 Liquidated Legg Mason International Low Volatility High Dividend ETF S000054583 10/31/2018 Legg Mason Low Volatility High Dividend ETF S000051686 10/31/2018 Legg Mason US Diversified Core ETF S000051685 Liquidated LEGG MASON FUNDS TRUST 811-23107 Clearbridge Real Estate Opportuntities Fund S000053074 Liquidated LEGG MASON GLOBAL ASSET 811-22338 BrandywineGLOBAL - Global Flexible Income Fund S000053934 12/31/2018 QS Global Market Neutral Fund S000051512 9/30/2018 MANAGEMENT TRUST RARE Global Infrastructure Value Fund S000053331 9/30/2018 BrandywineGLOBAL - Diversified US Large Cap Value Fund S000029727 9/30/2018 BrandywineGLOBAL - Dynamic US Large Cap Value Fund S000047047 9/30/2018 Martin Currie Emerging Markets Fund S000049068 9/30/2018 QS International Equity Fund S000036893 9/30/2018 QS Strategic Real Return Fund S000027987 9/30/2018 BrandywineGLOBAL - Alternative Credit Fund S000043089 10/31/2018 BrandywineGLOBAL - Global High Yield Fund S000037642 9/30/2018 BrandywineGLOBAL - Global Unconstrained Bond Fund S000031479 10/31/2018 ClearBridge International Growth Fund S000036166 10/31/2018 ClearBridge Small Cap Fund S000036165 10/31/2018 ClearBridge Value Trust S000036164 10/31/2018 BrandywineGLOBAL - Global Opportunities Bond Fund S000036894 12/31/2018 BrandywineGLOBAL - International Opportunities Bond Fund S000027197 12/31/2018 QS U.S. Small Capitalization Equity Fund S000036895 12/31/2018 LEGG MASON PARTNERS EQUITY TRUST 811-06444 ClearBridge Global Health Care Innovations Fund S000053237 Liquidated ClearBridge Aggressive Growth Fund S000016235 8/31/2018 ClearBridge All Cap Value Fund S000016245 9/30/2018 ClearBridge International Small Cap Fund S000029827 9/30/2018 ClearBridge Small Cap Value Fund S000016238 9/30/2018 QS Global Dividend Fund S000039864 9/30/2018 QS International Dividend Fund S000039863 Liquidated QS S&P 500 Index Fund S000004163 9/30/2018 ClearBridge Appreciation Fund S000016651 10/31/2018 ClearBridge Energy MLP & Infrastructure Fund S000041698 10/31/2018 ClearBridge International Value Fund S000016247 10/31/2018 ClearBridge Large Cap Value Fund S000016669 10/31/2018 ClearBridge Mid Cap Fund S000004162 10/31/2018 ClearBridge Mid Cap Growth Fund S000029718 10/31/2018 ClearBridge Select Fund S000039065 10/31/2018 ClearBridge Small Cap Growth Fund S000016663 10/31/2018 ClearBridge Sustainability Leaders Fund S000048737 10/31/2018 ClearBridge Tactical Dividend Income Fund S000016241 10/31/2018 QS Global Equity Fund S000016668 10/31/2018 ClearBridge Large Cap Growth Fund S000004161 11/30/2018 QS U.S. Large Cap Equity Fund S000022091 11/30/2018 ClearBridge Dividend Strategy Fund S000016665 12/31/2018 EnTrust Global - Alternative Core Fund S000025317 12/31/2018 LEGG MASON PARTNERS INSTITUTIONAL TRUST 811-06740 Western Asset Institutional Government Reserves S000016858 8/31/2018 Western Asset Institutional Liquid Reserves S000008908 8/31/2018 Western Asset Institutional U.S. Treasury Obligations Money Market Fund S000041891 8/31/2018 Western Asset Institutional U.S. Treasury Reserves S000008910 8/31/2018 Western Asset Select Tax Free Reserves S000008909 8/31/2018 Western Asset SMASh Series C Fund S000014682 2/28/2019 Western Asset SMASh Series EC Fund S000014683 2/28/2019 Western Asset SMASh Series M Fund S000014681 2/28/2019