SEC Company Response from NEW YORK LIFE INVESTMENTS FUNDS (CIK 0000787441) — Feb 14, 2022
NEW YORK LIFE INVESTMENTS FUNDS (CIK 0000787441)
Date: Feb. 14, 2022 · CIK: 0000787441 · Accession: 0001104659-22-022284
AI Filing Summary & Sentiment
File numbers found in text: 333-160918, 811-04550, 811-22321
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management, Disclosure Review Office Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Response to Comments on the Registration Statements (the “Registration Statements”) for MainStay Funds Trust (SEC File Nos. 333-160918 and 811-22321) and The MainStay Funds (SEC File Nos. 033-02610 and 811-04550) (collectively, the “Registrants”) relating to MainStay WMC Enduring Capital Fund, MainStay WMC Growth Fund, MainStay WMC Small Companies Fund, MainStay WMC Value Fund, MainStay WMC International Research Equity Fund and MainStay Balanced Fund (each a “Fund” and collectively, the “Funds”)
Dear Mr. Cowan:
This letter responds to comments provided by you on February 2, 2022 with respect to the Registration Statements. The Registration Statements were filed with the Securities and Exchange Commission on January 10, 2022 and relate to the Funds. On behalf of the Registrants, your comments and our responses thereto are provided below along with the corresponding updates to the Registration Statements included herein.
All defined terms in this letter have the same meaning as in the Registration Statements, except as otherwise defined herein.
Prospectus Comments – Summary Prospectus
COMMENTS APPLICABLE TO More than One Fund
Comment 1: In the paragraph preceding the Fees and Expenses table, delete information relating to the sales charge discount amounts for other Funds. Alternatively, modify the disclosure so that it includes the Fund and other certain Funds that would count within the $50,000 criterion for the discount.
Response: We have made the requested edit.
Comment 2: Delete the footnote to the Fees and Expenses table indicating that Other Expenses are based on estimated amounts for the current fiscal year. If expenses are being restated per Item 3 Instruction 3(d) of Form N-1A, please revise footnote accordingly.
Response: We have made the requested edit.
Comment 3: In the section entitled “Fees and Expenses of the Fund”, please add additional disclosure to more clearly describe the terms of the transfer agency fee waiver/expense reimbursement.
Response: We have made the requested edit.
Comment 4: Delete the word “Generally” from the following sentence:
Generally, an issuer of a security is considered to be a U.S. or foreign issuer based on the issuer’s “country of risk,” as determined by a third-party service provider such as Bloomberg.
Response: We have made the requested edit.
Comment 5: In the “Principal Investment Strategies” section, delete language regarding the subadvisor’s discretion to determine which countries are “emerging markets” countries. This should follow a third-party service provider’s classification or an index representative of emerging markets unless there are specific circumstances when a Fund would not follow a classification (and those circumstances should be specified).
Response: We have made the requested edit.
Comment 6: If a Fund will or has engaged in active/frequent trading resulting from the repositioning, please add corresponding principal strategy and risk disclosure in Item 4 and Item 9, including any tax consequences to new and existing shareholders as result of such portfolio turnover. Please also make sure item 16(e) also discusses the effect of portfolio turnover resulting from the repositioning.
Response: We have made the requested edit.
Comment 7: Revise the first paragraph in the “Past Performance” section to be more consistent with Item 4(b)(2)(i) of Form N-1A.
Response: We have made the requested edit.
Comment 8: Please move the description of the primary index in the “Past Performance” section from the narrative to a footnote in the Average Annual Total Returns table.
Response: We have made the requested edit.
Comment 9: In the “Past Performance” section, state that performance was not adjusted for each Fund’s fees and expenses, if true, but Class A’s performance was adjusted for the applicable sales load of each Fund.
Response: Historical performance was not adjusted to reflect any changes in fees and expenses that took place effective March 5, 2021. Class A sales charge amounts did not change on March 5, 2021.
Comment 10: Include disclosure required by Item 4(b), Instruction 2(b) of Form N-1A that explains why the additional index is being shown (e.g., by stating that the information shows how a Fund’s performance compares with the returns of an index of funds with similar investment objectives).
Response: We have made the requested edit.
MainStay WMC Enduring Capital Fund
Comment 1: In the “Principal Investment Strategies” section, why does the Fund reference both the Standard & Poor’s 500® Index and the Russell 3000® Index? The Russell 3000® Index appears to include the capitalization range of the S&P 500® Index.
Response: The Fund references both the Standard & Poor’s 500® Index and the Russell 3000® Index because these indices are the Fund’s primary and secondary benchmark. The Russell 3000® Index does include the capitalization range of the S&P 500® Index at this time, there is no guarantee this this will remain true in the future.
Comment 2: Please confirm whether investments in depositary receipts are part of the Fund’s principal investment strategies. If so, please reflect in the principal investment strategies section and add a corresponding principal risk factor.
Response: The Fund does not invest in depositary receipts as part of its principal investment strategy.
Comment 3: Please explain the following attributes in plain English and how the Subadvisor evaluates these attributes.
When purchasing stocks for the Fund, the Subadvisor looks for companies typically having some or all of the following attributes: resilient businesses, strong cash flow reinvestment and growth opportunities, owner-minded management teams who are skilled capital allocators, and stocks trading at reasonable valuations.
Response: We have made the requested edit.
Comment 4: Please include a separate risk factor for investing in securities of emerging market country issuers. See ADI 2020-11 Registered Funds’ Risk Disclosure Regarding Investments in Emerging Markets.
Response: We have made the requested edit.
MainStay WMC Growth Fund
Comment 1: Explain why there are fee waivers/reimbursements amounts shown for some of the other classes when the contractual expense cap appears to only be for Class I and Class R6.
Response: This Fund has two contractual expense cap agreements in place. The first relates to Class I and Class R6 shares specifically as described in relevant footnote. The second relates to limiting the transfer agency expenses for all share classes as described in the relevant footnote.
Comment 2: In the “Principal Investment Strategies” section, you state that “The Fund invests mainly in stocks of large capitalization U.S. companies…..”. What is meant by “mainly”? Does it mean “primarily”?
Response: We have revised our disclosure to state that: “The Fund invests primarily in stocks of large capitalization U.S. companies…”
Comment 3: In the “Market Capitalization Risk” tile, please explain why the disclosure addresses the risks associated with investing in small- and mid-cap companies if the Fund mainly invests in large-cap companies.
Response: The Fund may still invest in small- and mid-cap companies, and the Market Capitalization Risk tile is meant to address the risks associated with those investments as well as investments in large-cap companies.
Comment 4: In the “Past Performance” section, please clarify if Class A shares were acquired in Keystone Large Cap Growth Fund merger like Class I.
Response: We have made the requested clarification.
Comment 5: In the “Past Performance” section, it appears there were multiple subadvisors prior to March 5, 2021. Please revise as appropriate (e.g., prior subadvisors and predecessor to the Fund).
Response: We have made the requested clarification.
MainStay WMC Small Companies Fund
Comment 1: Please explain why some share classes show 0.00% in the Waiver/Reimbursement line.
Response: This line item pertains to the cap on transfer agency expenses described in the footnotes. This cap is applied on a class-by-class basis.
Comment 2: Please confirm whether investments in depositary receipts are part of the Fund’s principal investment strategies. If so, please reflect in the principal investment strategies section and add a corresponding principal risk factor.
Response: The Fund does not invest in depositary receipts as part of its principal investment strategy.
Comment 3: Revise the following statement to be more “plain English”.
The Subadvisor employs a traditional, bottom-up fundamental research approach to identify securities with potential positive inflections in business fundamentals that the Subadvisor believes have the most potential to appreciate, while seeking to limit exposure to risk.
Response: We have revised the disclosure to read as follows:
The Subadvisor employs a bottom-up fundamental research approach to identify companies with potential positive changes in their business that the Subadvisor believes may lead to outperformance, while seeking to limit exposure to risk.
Comment 4: Please add a risk factor to describe the risks associated with investments in micro-cap stocks.
Response: We have made the requested revision.
MainStay WMC Value Fund
Comment 1: Explain why there are fee waivers/reimbursements amounts shown for some of the other classes when the contractual expense cap appears to only be for Class I and Class R6.
Response: This Fund has two contractual expense cap agreements in place. The first relates to Class I and Class R6 shares specifically as described in relevant footnote. The second relates to limiting the transfer agency expenses for all share classes as described in the relevant footnote.
Comment 2: In the “Principal Investment Strategies” section, indicate that the Fund may invest in American Depositary Receipts.
Response: We have made the requested revision.
Comment 3: In the section entitled “Principal Investment Strategies”, please include disclosure explaining the criteria for determining the quality of a company.
The Subadvisor employs a “bottom-up” approach to investment research, and seeks to capitalize on investor behavioral biases by investing in companies with an attractive combination of valuation, quality, and capital return, and by taking a long-term view.
Response: We have made the requested revision.
Comment 4: Will the Fund invest in Growth Stocks, Convertible Securities and Dividend-Paying Stocks as part of its principal investment strategies?
Response: The Fund does not invest in these types of securities as part of its principal investment strategy.
Comment 5: Include a separate risk factor for investing in securities of emerging market country issuers. See ADI 2020-11 Registered Funds’ Risk Disclosure Regarding Investments in Emerging Markets.
Response: We have made the requested edit.
MainStay WMC International Research Equity Fund
Comment 1: Why are you showing waiver amounts for classes other than Class I. This does not match the language in the footnote. Please revise.
Response: We have revised the footnote accordingly.
Comment 2: Explain what is meant by “styles” in the following sentence:
The Subadvisor seeks to develop a portfolio that is generally broadly diversified across issuers, industries, countries, and styles.
Response: By “style” we mean “investment styles and characteristics”. We have revised the disclosure to reflect this.
Comment 3: Include a risk factor for “Convertible Securities”.
Response: We have made the requested edit.
Comment 4: Add a risk factor regarding investments in Chinese issuers, if applicable.
Response: We have added risk factor language regarding investments in Chinese issuers.
Comment 5: Include a risk factor for “Growth Stocks”.
Response: We have made the requested edit.
Comment 6: Is including “Liquidity and Valuation Risk” for this Fund correct? Please disclose the types of illiquid securities in which the Fund invests as part of its principal investment strategies.
Response: We have deleted this risk factor.
Comment 7: Is the Fund currently focused on any single country? If so, please disclose here and in the principal investment strategies (and add related risks). Also, if Brexit is a principal risk to this Fund, please disclose.
Response: The Fund is not focused on any single country as part of its principal investment strategy. However, we have added risk factor language regarding Brexit.
Comment 8: In the “Past Performance” section, it appears there were multiple subadvisors prior to March 5, 2021. Please revise as appropriate (e.g., prior subadvisors and predecessor to the Fund).
Response: We have made the requested clarification.
MAINSTAY BALANCED FUND
Comment 1: Please confirm supplementally that if the Fund’s investments in other investment companies are expected to exceed 0.01% of the Fund’s average net assets, it will add the acquired fund fees and expenses row in the fee table.
Response: We hereby confirm that the acquired fund fees and expenses row will be included as applicable.
Comment 2: Please confirm supplementally whether the Fund will invest in convertible securities as part of its principal investment strategies. If so, please disclose in the principal investment strategies section and include a corresponding principal risk.
Response: We hereby confirm that the Fund does not currently invest in convertible securities as part of its principal investment strategies.
Comment 3: In the section entitled “Principal Investment Strategies”, please include disclosure describing the Fund’s fundamental policy to be a “balanced fund.” Please further disclose in both Items 4 and 9 that this fundamental policy cannot be changed without shareholder approval.
Response: We have made the requested edit.
Comment 4: In the section entitled “Principal Investment Strategies”, please include disclosure addressing how the Subadvisor determines a company to be of “high quality.” Please include similar disclosure in the “Equity Investment Process” sub-section.
Response: We have made the requested edit.
Comment 5: In the section entitled “Principal Investment Strategies”, please disclose the applicable criteria as to credit quality and duration for the Fund’s investments in debt securities. If the Subadvisor has set the minimum credit quality at investment grade for any fixed income securities, please disclose accordingly.
Response: We have made the requested edit.
Comment 6: In the section entitled “Principal Investment Strategies”, please include an example of duration (e.g., a duration of “three” means that a security’s price would be expected to decrease by approximately 3% with a 1% increase in interest rates).
Response: We have made the requested edit.
Comment 7: In the section entitled “Principal Risks”, please revise the “Debt Securities Risk” to provide additional detail regarding the impact of the current low interest rate environment.
Response: We have made the requested edit.
Comment 8: In the section entitled “Principal Risks”, please update the “Floating Rate Notes and Variable Rate Notes Risk” to address how the expected discontinuation of LIBOR could affect the Fund’s investments.
Response: We have made the requested edit.
Comment 9: In the section entitled “Principal Risks”, please confirm whether any updates to the “Liquidity and Valuation Risk” tile are necessary based on the Fund’s pr
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filename1.htm
THE MAINSTAY FUNDS
MAINSTAY FUNDS TRUST
51 MADISON AVENUE
NEW YORK, NEW YORK 10010
VIA EDGAR CORRESPONDENCE
February 14, 2022
Mr. Mark Cowan
Division of Investment Management, Disclosure Review Office
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Response to Comments on the Registration Statements (the “Registration
Statements”) for MainStay Funds Trust (SEC File Nos. 333-160918 and 811-22321) and The MainStay Funds (SEC File Nos. 033-02610 and
811-04550) (collectively, the “Registrants”) relating to MainStay WMC Enduring Capital Fund, MainStay WMC Growth Fund, MainStay
WMC Small Companies Fund, MainStay WMC Value Fund, MainStay WMC International Research Equity Fund and MainStay Balanced Fund (each a
“Fund” and collectively, the “Funds”)
Dear Mr. Cowan:
This letter responds to comments provided by
you on February 2, 2022 with respect to the Registration Statements. The Registration Statements were filed with the Securities and
Exchange Commission on January 10, 2022 and relate to the Funds. On behalf of the Registrants, your comments and our responses
thereto are provided below along with the corresponding updates to the Registration Statements included herein.
All defined terms in this letter have the same meaning as in the Registration
Statements, except as otherwise defined herein.
Prospectus Comments – Summary Prospectus
COMMENTS APPLICABLE TO
More than One Fund
Comment 1: In the paragraph preceding the Fees and Expenses
table, delete information relating to the sales charge discount amounts for other Funds. Alternatively, modify the disclosure so that
it includes the Fund and other certain Funds that would count within the $50,000 criterion for the discount.
Response: We have made the requested edit.
Comment 2: Delete the footnote to the Fees and Expenses
table indicating that Other Expenses are based on estimated amounts for the current fiscal year. If expenses are being restated per Item
3 Instruction 3(d) of Form N-1A, please revise footnote accordingly.
Response: We have made the requested edit.
Comment 3: In the section entitled
“Fees and Expenses of the Fund”, please add additional disclosure to more clearly describe the terms of the transfer
agency fee waiver/expense reimbursement.
Response: We have made the requested
edit.
Comment 4: Delete the word “Generally” from
the following sentence:
Generally, an issuer of a security is considered to be a U.S. or foreign
issuer based on the issuer’s “country of risk,” as determined by a third-party service provider such as Bloomberg.
Response: We have made the requested edit.
Comment 5: In the “Principal
Investment Strategies” section, delete language regarding the subadvisor’s discretion to determine which countries
are “emerging markets” countries. This should follow a third-party service provider’s classification or an index
representative of emerging markets unless there are specific circumstances when a Fund would not follow a classification (and those
circumstances should be specified).
Response: We have made the requested edit.
Comment 6: If
a Fund will or has engaged in active/frequent trading resulting from the repositioning, please add corresponding principal strategy and
risk disclosure in Item 4 and Item 9, including any tax consequences to new and existing shareholders as result of such portfolio
turnover. Please also make sure item 16(e) also discusses the effect of portfolio turnover resulting from the repositioning.
Response: We have made the requested edit.
Comment 7: Revise the first paragraph in the “Past
Performance” section to be more consistent with Item 4(b)(2)(i) of Form N-1A.
Response: We have made the requested edit.
Comment 8: Please move the description of the primary
index in the “Past Performance” section from the narrative to a footnote in the Average Annual Total Returns table.
Response: We have made the requested edit.
Comment 9: In the “Past Performance”
section, state that performance was not adjusted for each Fund’s fees and expenses, if true, but Class A’s performance was
adjusted for the applicable sales load of each Fund.
Response: Historical performance was not adjusted to
reflect any changes in fees and expenses that took place effective March 5, 2021. Class A sales charge amounts did not change on March
5, 2021.
Comment 10: Include disclosure required by Item 4(b),
Instruction 2(b) of Form N-1A that explains why the additional index is being shown (e.g., by stating that the information shows how a
Fund’s performance compares with the returns of an index of funds with similar investment objectives).
Response: We have made the requested edit.
MainStay WMC Enduring
Capital Fund
Comment 1: In the “Principal Investment Strategies”
section, why does the Fund reference both the Standard & Poor’s 500® Index and the Russell 3000®
Index? The Russell 3000® Index appears to include the capitalization range of the S&P 500® Index.
Response: The Fund references both the Standard &
Poor’s 500® Index and the Russell 3000® Index because these indices are the Fund’s primary and
secondary benchmark. The Russell 3000® Index does include the capitalization range of the S&P 500® Index
at this time, there is no guarantee this this will remain true in the future.
Comment 2: Please confirm whether investments in
depositary receipts are part of the Fund’s principal investment strategies. If so, please reflect in the principal investment
strategies section and add a corresponding principal risk factor.
Response: The Fund does not invest in depositary receipts
as part of its principal investment strategy.
Comment 3: Please explain the following
attributes in plain English and how the Subadvisor evaluates these attributes.
When purchasing stocks for the Fund, the Subadvisor looks for companies
typically having some or all of the following attributes: resilient businesses, strong cash flow reinvestment and growth opportunities,
owner-minded management teams who are skilled capital allocators, and stocks trading at reasonable valuations.
Response: We have made the requested edit.
Comment 4: Please include a separate risk factor
for investing in securities of emerging market country issuers. See ADI 2020-11 Registered Funds’ Risk Disclosure Regarding
Investments in Emerging Markets.
Response: We have made the requested edit.
MainStay WMC Growth Fund
Comment 1: Explain why there are fee
waivers/reimbursements amounts shown for some of the other classes when the contractual expense cap appears to only be for Class I
and Class R6.
Response: This Fund has two contractual expense cap agreements
in place. The first relates to Class I and Class R6 shares specifically as described in relevant footnote. The second relates to limiting
the transfer agency expenses for all share classes as described in the relevant footnote.
Comment 2: In the “Principal Investment Strategies”
section, you state that “The Fund invests mainly in stocks of large capitalization U.S. companies…..”. What is meant
by “mainly”? Does it mean “primarily”?
Response: We have revised our disclosure to state that:
“The Fund invests primarily in stocks of large capitalization U.S. companies…”
Comment 3: In the “Market Capitalization Risk”
tile, please explain why the disclosure addresses the risks associated with investing in small- and mid-cap companies if the Fund mainly
invests in large-cap companies.
Response: The Fund may still invest in small- and mid-cap
companies, and the Market Capitalization Risk tile is meant to address the risks associated with those investments as well as investments
in large-cap companies.
Comment 4: In the “Past Performance”
section, please clarify if Class A shares were acquired in Keystone Large Cap Growth Fund merger like Class I.
Response: We have made the requested clarification.
Comment 5: In the “Past Performance”
section, it appears there were multiple subadvisors prior to March 5, 2021. Please revise as appropriate (e.g., prior subadvisors and
predecessor to the Fund).
Response: We have made the requested clarification.
MainStay WMC Small Companies
Fund
Comment 1: Please explain why some share classes show
0.00% in the Waiver/Reimbursement line.
Response: This line item pertains to the cap on transfer
agency expenses described in the footnotes. This cap is applied on a class-by-class basis.
Comment 2: Please confirm whether investments in
depositary receipts are part of the Fund’s principal investment strategies. If so, please reflect in the principal investment
strategies section and add a corresponding principal risk factor.
Response: The Fund does not invest in depositary receipts
as part of its principal investment strategy.
Comment 3: Revise the following statement to be more
“plain English”.
The Subadvisor employs a traditional, bottom-up fundamental research
approach to identify securities with potential positive inflections in business fundamentals that the Subadvisor believes have the most
potential to appreciate, while seeking to limit exposure to risk.
Response: We have revised the disclosure to read as follows:
The Subadvisor employs a bottom-up fundamental research approach to
identify companies with potential positive changes in their business that the Subadvisor believes may lead to outperformance, while seeking
to limit exposure to risk.
Comment 4: Please add a risk factor to describe the risks
associated with investments in micro-cap stocks.
Response: We have made the requested revision.
MainStay WMC Value Fund
Comment 1: Explain why there are fee waivers/reimbursements
amounts shown for some of the other classes when the contractual expense cap appears to only be for Class I and Class R6.
Response: This Fund has two contractual expense cap agreements
in place. The first relates to Class I and Class R6 shares specifically as described in relevant footnote. The second relates to limiting
the transfer agency expenses for all share classes as described in the relevant footnote.
Comment 2: In the “Principal Investment Strategies”
section, indicate that the Fund may invest in American Depositary Receipts.
Response: We have made the requested revision.
Comment 3: In
the section entitled “Principal Investment Strategies”, please include disclosure explaining the criteria for determining
the quality of a company.
The Subadvisor employs a “bottom-up” approach to investment
research, and seeks to capitalize on investor behavioral biases by investing in companies with an attractive combination of valuation,
quality, and capital return, and by taking a long-term view.
Response: We have made the requested revision.
Comment 4: Will the Fund invest in Growth Stocks, Convertible
Securities and Dividend-Paying Stocks as part of its principal investment strategies?
Response: The Fund does not invest in these types of
securities as part of its principal investment strategy.
Comment 5: Include a separate risk
factor for investing in securities of emerging market country issuers. See ADI 2020-11 Registered Funds’ Risk Disclosure
Regarding Investments in Emerging Markets.
Response: We have made the requested edit.
MainStay WMC International
Research Equity Fund
Comment
1: Why are you showing waiver amounts for classes other than Class I. This does not match the language in the footnote. Please
revise.
Response: We have revised the footnote
accordingly.
Comment 2: Explain what is meant by “styles”
in the following sentence:
The Subadvisor seeks to develop a portfolio that is generally
broadly diversified across issuers, industries, countries, and styles.
Response: By “style” we mean “investment
styles and characteristics”. We have revised the disclosure to reflect this.
Comment 3: Include a risk factor for “Convertible
Securities”.
Response: We have made the requested edit.
Comment 4: Add a risk factor regarding investments in
Chinese issuers, if applicable.
Response: We have added risk factor language regarding
investments in Chinese issuers.
Comment 5: Include a risk factor for “Growth Stocks”.
Response: We have made the requested edit.
Comment 6: Is including “Liquidity and Valuation
Risk” for this Fund correct? Please disclose the types of illiquid securities in which the Fund invests as part of its principal
investment strategies.
Response: We have deleted this risk factor.
Comment 7: Is the Fund currently focused on any single
country? If so, please disclose here and in the principal investment strategies (and add related risks). Also, if Brexit is a principal
risk to this Fund, please disclose.
Response: The Fund is not focused on any single country
as part of its principal investment strategy. However, we have added risk factor language regarding Brexit.
Comment 8: In the “Past Performance”
section, it appears there were multiple subadvisors prior to March 5, 2021. Please revise as appropriate (e.g., prior subadvisors and
predecessor to the Fund).
Response: We have made the requested clarification.
MAINSTAY BALANCED FUND
Comment 1: Please confirm supplementally
that if the Fund’s investments in other investment companies are expected to exceed 0.01% of the Fund’s average net assets,
it will add the acquired fund fees and expenses row in the fee table.
Response: We hereby confirm that
the acquired fund fees and expenses row will be included as applicable.
Comment 2: Please confirm supplementally
whether the Fund will invest in convertible securities as part of its principal investment strategies. If so, please disclose in the principal
investment strategies section and include a corresponding principal risk.
Response: We
hereby confirm that the Fund does not currently invest in convertible securities as part of its principal investment strategies.
Comment 3: In the section entitled
“Principal Investment Strategies”, please include disclosure describing the Fund’s fundamental policy to be a
“balanced fund.” Please further disclose in both Items 4 and 9 that this fundamental policy cannot be changed without shareholder
approval.
Response: We have made the requested
edit.
Comment 4: In the section entitled
“Principal Investment Strategies”, please include disclosure addressing how the Subadvisor determines a company to
be of “high quality.” Please include similar disclosure in the “Equity Investment Process” sub-section.
Response: We
have made the requested edit.
Comment 5: In the section entitled
“Principal Investment Strategies”, please disclose the applicable criteria as to credit quality and duration for the
Fund’s investments in debt securities. If the Subadvisor has set the minimum credit quality at investment grade for any fixed income
securities, please disclose accordingly.
Response: We
have made the requested edit.
Comment 6: In the section entitled
“Principal Investment Strategies”, please include an example of duration (e.g., a duration of “three” means
that a security’s price would be expected to decrease by approximately 3% with a 1% increase in interest rates).
Response: We
have made the requested edit.
Comment 7: In the section entitled
“Principal Risks”, please revise the “Debt Securities Risk” to provide additional detail regarding the
impact of the current low interest rate environment.
Response: We
have made the requested edit.
Comment 8: In the section entitled
“Principal Risks”, please update the “Floating Rate Notes and Variable Rate Notes Risk” to address how
the expected discontinuation of LIBOR could affect the Fund’s investments.
Response: We
have made the requested edit.
Comment 9: In the section entitled
“Principal Risks”, please confirm whether any updates to the “Liquidity and Valuation Risk” tile are necessary
based on the Fund’s pr