CORRESP 1 filename1.htm corresp
 
April 30, 2010
(LEGG MASON GLOBAL ASSET MANAGEMENT LOGO)
 
Prospectus
 
Legg Mason Western Asset
Variable Global High Yield Bond Portfolio
 
Class I Shares
 
 
Shares of the fund are offered only to insurance company separate accounts, which fund certain variable annuity and variable life insurance contracts, and to qualified retirement and pension plans. This Prospectus should be read together with the prospectus for those contracts.
 
The Securities and Exchange Commission has not approved or disapproved these securities or determined whether this Prospectus is accurate or complete. Any statement to the contrary is a crime.
 
INVESTMENT PRODUCTS: NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE


 

2 | Legg Mason Western Asset Variable Global High Yield Bond Portfolio

 
Investment objective
 
The fund seeks to maximize total return, consistent with the preservation of capital.
 
Fees and expenses of the fund
 
The accompanying table describes the fees and expenses that you may pay if you buy and hold Class I shares of the fund.
 
The fee table and expense example do not reflect expenses incurred from investing through a separate account or qualified plan and do not reflect variable annuity or life insurance contract charges. If they did, the returns would be lower and the overall fees and expenses would be higher than those shown. Detailed information about the cost of investing in this fund through a separate account or qualified plan is presented in the contract prospectus through which the fund’s shares are offered to you.
 
             
 Shareholder fees (paid directly from your investment) (%)
 
Maximum sales charge (load) imposed on purchases     N/A      
Maximum deferred sales charge (load)     N/A      
 
             
 Annual fund operating expenses (expenses that you pay each year as a percentage of the value of your investment) (%)
 
Management fees     0.80      
Distribution and service (12b-1) fees     None       
Other expenses     0.11      
Total annual fund operating expenses     0.91      
 
Example
This example is intended to help you compare the cost of investing in Class I shares of the fund with the cost of investing in other mutual funds. The example does not include expenses incurred from investing through a separate account or qualified plan. If the example included these expenses, the figures shown would be higher. The example assumes:
 
•  You invest $10,000 in the fund for the time periods indicated
 
•  Your investment has a 5% return each year and the fund’s operating expenses remain the same
 
•  You reinvest all distributions and dividends without a sales charge
 
Although your actual costs may be higher or lower, based on these assumptions your costs would be:
 
                     
 Number of years you own your shares ($)   1 year   3 years   5 years   10 years    
 
Class I shares (with or without redemption at end of period)   93   291   505   1,120    


 

April 30, 2010
(LEGG MASON GLOBAL ASSET MANAGEMENT LOGO)
 
Prospectus
 
Legg Mason Western Asset
Variable Global High Yield Bond Portfolio
 
Class II Shares
 
 
Shares of the fund are offered only to insurance company separate accounts, which fund certain variable annuity and variable life insurance contracts, and to qualified retirement and pension plans. This Prospectus should be read together with the prospectus for those contracts.
 
The Securities and Exchange Commission has not approved or disapproved these securities or determined whether this Prospectus is accurate or complete. Any statement to the contrary is a crime.
 
INVESTMENT PRODUCTS: NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE


 

2 | Legg Mason Western Asset Variable Global High Yield Bond Portfolio

Fees and expenses of the fund
 
The accompanying table describes the fees and expenses that you may pay if you buy and hold Class II shares of the fund.
 
The fee table and expense example do not reflect expenses incurred from investing through a separate account or qualified plan and do not reflect variable annuity or life insurance contract charges. If they did, the returns would be lower and the overall fees and expenses would be higher than those shown. Detailed information about the cost of investing in this fund through a separate account or qualified plan is presented in the contract prospectus through which the fund’s shares are offered to you.
 
             
 Shareholder fees (paid directly from your investment) (%)
 
Maximum sales charge (load) imposed on purchases     N/A      
Maximum deferred sales charge (load)     N/A      
 
             
 Annual fund operating expenses (expenses that you pay each year as a percentage of the value of your investment) (%)
 
Management fees     0.80      
Distribution and service (12b-1) fees     0.25      
Other expenses     0.19      
Total annual fund operating expenses     1.24      
 
Example
This example is intended to help you compare the cost of investing in Class II shares of the fund with the cost of investing in other mutual funds. The example does not include expenses incurred from investing through a separate account or qualified plan. If the example included these expenses, the figures shown would be higher. The example assumes:
 
•  You invest $10,000 in the fund for the time periods indicated
 
•  Your investment has a 5% return each year and the fund’s operating expenses remain the same
 
•  You reinvest all distributions and dividends without a sales charge
 
Although your actual costs may be higher or lower, based on these assumptions your costs would be:
 
                     
 Number of years you own your shares ($)   1 year   3 years   5 years   10 years    
 
Class II shares (with or without redemption at end of period)   126   393   680   1,500    


 

 
April 30, 2010
(LEGG MASON GLOBAL ASSET MANAGEMENT LOGO)
 
Prospectus
 
Legg Mason Western Asset
Variable Diversified Strategic Income Portfolio
 
 
Shares of the fund are offered only to insurance company separate accounts, which fund certain variable annuity and variable life insurance contracts, and to qualified retirement and pension plans. This Prospectus should be read together with the prospectus for those contracts.
 
The Securities and Exchange Commission has not approved or disapproved these securities or determined whether this Prospectus is accurate or complete. Any statement to the contrary is a crime.
 
INVESTMENT PRODUCTS: NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE


 

2 | Legg Mason Western Asset Variable Diversified Strategic Income Portfolio

 
Fees and expenses of the fund
 
The accompanying table describes the fees and expenses that you may pay if you buy and hold shares of the fund.
 
The fee table and expense example do not reflect expenses incurred from investing through a separate account or qualified plan and do not reflect variable annuity or life insurance contract charges. If they did, the returns would be lower and the overall fees and expenses would be higher than those shown. Detailed information about the cost of investing in this fund through a separate account or qualified plan is presented in the contract prospectus through which the fund’s shares are offered to you.
 
             
 Shareholder fees (paid directly from your investment) (%)
 
Maximum sales charge (load) imposed on purchases     N/A      
Maximum deferred sales charge (load)     N/A      
 
             
 Annual fund operating expenses (expenses that you pay each year as a percentage of the value of your investment) (%)
 
Management fees     0.65      
Distribution and service (12b-1) fees     None      
Other expenses     0.30      
Total annual fund operating expenses     0.95      
 
Example
This example is intended to help you compare the cost of investing in the fund with the cost of investing in other mutual funds. The example does not include expenses incurred from investing through a separate account or qualified plan. If the example included these expenses, the figures shown would be higher. The example assumes:
 
•  You invest $10,000 in the fund for the time periods indicated
 
•  Your investment has a 5% return each year and the fund’s operating expenses remain the same
 
•  You reinvest all distributions and dividends without a sales charge
 
Although your actual costs may be higher or lower, based on these assumptions your costs would be:
 
                                     
 Number of years you own your shares ($)   1 year   3 years   5 years   10 years    
 
With or without redemption at end of period     97       303       526       1,167      


 

 
April 30, 2010
(LEGG MASON GLOBAL ASSET MANAGEMENT LOGO)
 
Prospectus
 
Legg Mason Western Asset
Variable Strategic Bond Portfolio
 
Class I Shares
 
 
Shares of the fund are offered only to insurance company separate accounts, which fund certain variable annuity and variable life insurance contracts, and to qualified retirement and pension plans. This Prospectus should be read together with the prospectus for those contracts.
 
The Securities and Exchange Commission has not approved or disapproved these securities or determined whether this Prospectus is accurate or complete. Any statement to the contrary is a crime.
 
INVESTMENT PRODUCTS: NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE


 

2 | Legg Mason Western Asset Variable Strategic Bond Portfolio

 
Fees and expenses of the fund
 
The accompanying table describes the fees and expenses that you may pay if you buy and hold Class I shares of the fund.
 
The fee table and expense example do not reflect expenses incurred from investing through a separate account or qualified plan and do not reflect variable annuity or life insurance contract charges. If they did, the returns would be lower and the overall fees and expenses would be higher than those shown. Detailed information about the cost of investing in this fund through a separate account or qualified plan is presented in the contract prospectus through which the fund’s shares are offered to you.
 
             
 Shareholder fees (paid directly from your investment) (%)
 
Maximum sales charge (load) imposed on purchases     N/A      
Maximum deferred sales charge (load)     N/A      
 
             
 Annual fund operating expenses (expenses that you pay each year as a percentage of the value of your investment) (%)
 
Management fees     0.65      
Distribution and service (12b-1) fees     None      
Other expenses     0.31      
Total annual fund operating expenses     0.96      
 
Example
This example is intended to help you compare the cost of investing in Class I shares of the fund with the cost of investing in other mutual funds. The example does not include expenses incurred from investing through a separate account or qualified plan. If the example included these expenses, the figures shown would be higher. The example assumes:
 
•  You invest $10,000 in the fund for the time periods indicated
 
•  Your investment has a 5% return each year and the fund’s operating expenses remain the same
 
•  You reinvest all distributions and dividends without a sales charge
 
Although your actual costs may be higher or lower, based on these assumptions your costs would be:
 
                     
 Number of years you own your shares ($)   1 year   3 years   5 years   10 years    
 
Class I shares (with or without redemption at end of period)   98   306   531   1,177    


 

 
April 30, 2010
(LEGG MASON GLOBAL ASSET MANAGEMENT LOGO)
 
Prospectus
 
Legg Mason Western Asset
Variable Strategic Bond Portfolio
 
Class II Shares
 
 
Shares of the fund are offered only to insurance company separate accounts, which fund certain variable annuity and variable life insurance contracts, and to qualified retirement and pension plans. This Prospectus should be read together with the prospectus for those contracts.
 
The Securities and Exchange Commission has not approved or disapproved these securities or determined whether this Prospectus is accurate or complete. Any statement to the contrary is a crime.
 
INVESTMENT PRODUCTS: NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE


 

2 | Legg Mason Western Asset Variable Strategic Bond Portfolio

 
Investment objective
 
The fund seeks to maximize total return, consistent with the preservation of capital.
 
Fees and expenses of the fund
 
The accompanying table describes the fees and expenses that you may pay if you buy and hold Class II shares of the fund.
 
The fee table and expense example do not reflect expenses incurred from investing through a separate account or qualified plan and do not reflect variable annuity or life insurance contract charges. If they did, the returns would be lower and the overall fees and expenses would be higher than those shown. Detailed information about the cost of investing in this fund through a separate account or qualified plan is presented in the contract prospectus through which the fund’s shares are offered to you.
 
         
 Shareholder fees (paid directly from your investment) (%)
 
Maximum sales charge (load) imposed on purchases   N/A    
Maximum deferred sales charge (load)   N/A    
 
             
 Annual fund operating expenses (expenses that you pay each year as a percentage of the value of your investment) (%)
 
Management fees     0.65      
Distribution and service (12b-1) fees     0.25      
Other expenses1     2.02      
Total annual fund operating expenses     2.92      
Fees forgone and/or expenses reimbursed1     (1.67)      
Total annual fund operating expenses after forgoing fees and/or reimbursing expenses     1.25      
 
1  The manager has agreed to forgo fees and/or reimburse operating expenses (other than interest, brokerage, taxes and extraordinary expenses) so that total annual operating expenses are not expected to exceed 1.25%. This arrangement cannot be terminated prior to December 31, 2011 without the Board of Trustees’ consent. The manager is permitted to recapture amounts forgone or reimbursed to the class during the same fiscal year if the class’ total annual operating expenses have fallen to a level below the limits described above.
 
Example
This example is intended to help you compare the cost of investing in Class II shares of the fund with the cost of investing in other mutual funds. The example does not include expenses incurred from investing through a separate account or qualified plan. If the example included these expenses, the figures shown would be higher. The example assumes:
 
•  You invest $10,000 in the fund for the time periods indicated
 
•  Your investment has a 5% return each year and the fund’s operating expenses remain the same
 
•  You reinvest all distributions and dividends without a sales charge
 
Although your actual costs may be higher or lower, based on these assumptions your costs would be:
 
                     
 Number of years you own your shares ($)   1 year   3 years   5 years   10 years    
 
Class II shares (with or without redemption at end of period)   127   745   1,390   3,122    


 

Bingham McCutchen LLP
One Federal Street
Boston, MA 02110
April 5, 2010
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re:   Legg Mason Partners Variable Income Trust
(filing relates to Legg Mason Western Asset Variable Diversified Strategic Income Portfolio, Legg Mason Western Asset Variable Global High Yield Bond Portfolio and Legg Mason Western Asset Variable Strategic Bond Portfolio (the “Funds”))
(File Nos. 33-40603 and 811-06310)
Ladies and Gentlemen:
     On behalf of Legg Mason Partners Variable Income Trust, a Maryland business trust (the “Trust”), we are hereby filing copies of the current drafts of the “Fee table,” “Example” and related footnotes to be included in the Funds’ prospectuses. The Funds’ prospectuses were included in Post-Effective Amendment No. 55 to the registration statement for the Trust (the “Amendment”), which was filed with the Commission on Form N-1A pursuant to Rule 485(a) under the Securities Act of 1933, as amended, on January 29, 2010.
     We are filing copies of the draft “Fee table,” “Example” and related footnotes for the Funds in accordance with the Staff’s comments provided by Valerie Lithotomos in February 2008 in connection with Post-Effective Amendment No. 94 to the registration statement for Legg Mason Partners Income Trust.
     The Amendment was filed in order to reflect the enhanced disclosure and new prospectus delivery option for registered open-end investment companies as set forth in Form N-1A, as amended.
     Please call Michelle Cirillo at (617) 951-8029 or the undersigned at (617) 951-8693 with any comments or questions relating to the filing.
Sincerely,
/s/ Matthew Prasse
Matthew Prasse