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SEC Company Response from NEW YORK LIFE INVESTMENTS FUNDS (CIK 0000787441) — Dec 23, 2004

NEW YORK LIFE INVESTMENTS FUNDS (CIK 0000787441)
Date: Dec. 23, 2004 · CIK: 0000787441 · Accession: 0000950123-04-015194

AI Filing Summary & Sentiment

File numbers found in text: 811-04550

Date
December 23, 2004
Author
/s/ Erin G. Wagner
Form
CORRESP
Company
NEW YORK LIFE INVESTMENTS FUNDS (CIK 0000787441)

Letter

December 23, 2004 VIA EDGAR Keith O'Connell Division of Investment Management Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0506

RE: The MainStay Funds ("Trust"), File Nos. 033-02610, 811-04550

Dear Mr. O'Connell:

This letter responds to a comment you provided telephonically on December 13, 2004, regarding Post-Effective Amendment No. 67 to the Trust's registration statement on Form N-1A ("PEA 67") concerning the addition of Class I shares of the Common Stock Fund.

You requested that the Trust disclose the minimum subsequent investment amount for individual investors in Class I shares. We will revise the language to clarify that there is no minimum amount for subsequent investments for these investors.

In addition to this comment, you requested that the Registrant make certain representations concerning PEA 67 and the response being made to the comment received. These representations are included as an exhibit to this letter.

If you have any questions or comments in connection with the foregoing, please contact the undersigned at 202.261.3317 or Brendan C. Fox at 202.261.3381.

Sincerely,
/s/ Erin G. Wagner

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>y04154corresp1.txt
<DESCRIPTION>SEC RESPONSE LETTER
<TEXT>
<PAGE>

                                   Dechert LLP
                                1775 I Street, NW
                              Washington DC, 20006

December 23, 2004

VIA EDGAR

Keith O'Connell
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549-0506

RE:      The MainStay Funds ("Trust"), File Nos. 033-02610, 811-04550

Dear Mr. O'Connell:

         This letter responds to a comment you provided telephonically on
December 13, 2004, regarding Post-Effective Amendment No. 67 to the Trust's
registration statement on Form N-1A ("PEA 67") concerning the addition of Class
I shares of the Common Stock Fund.

         You requested that the Trust disclose the minimum subsequent investment
amount for individual investors in Class I shares. We will revise the language
to clarify that there is no minimum amount for subsequent investments for these
investors.

         In addition to this comment, you requested that the Registrant make
certain representations concerning PEA 67 and the response being made to the
comment received. These representations are included as an exhibit to this
letter.

         If you have any questions or comments in connection with the foregoing,
please contact the undersigned at 202.261.3317 or Brendan C. Fox at
202.261.3381.

                                                     Sincerely,

                                                     /s/ Erin G. Wagner

                                                     Erin G. Wagner

cc:      Marguerite E. H. Morrison, Esq.
         Michael Hession, Esq.
         Brendan Fox

</TEXT>
</DOCUMENT>