SEC Company Response from MAINSTAY FUNDS TRUST (CIK 0001469192) — Mar 11, 2020
MAINSTAY FUNDS TRUST (CIK 0001469192)
Date: March 11, 2020 · CIK: 0001469192 · Accession: 0001104659-20-031645
AI Filing Summary & Sentiment
File numbers found in text: 333-235812, 333-235813, 811-22321
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Response to Comments on Pre-Effective Amendment #1 to the two N-14 filings (the “Proxy Statements/Prospectuses”) for MainStay Funds Trust (the “Registrant”) (SEC File Nos. 333-235813 and 811-22321); and (SEC File Nos 333-235812 and 811-22321)
Dear Mr. Cowan:
This letter responds to comments provided by you electronically on March 3, 2020 and telephonically by Mr. Jason Fox on March 5, 2020 with respect to the Proxy Statements/Prospectuses. The Proxy Statements/Prospectuses were filed with the Securities and Exchange Commission on March 2, 2020 and relate to the following proposed mergers: (i) MainStay Cushing Renaissance Advantage Fund with and into MainStay CBRE Global Infrastructure Fund; and (ii) MainStay Cushing Energy Income Fund with and into MainStay CBRE Global Infrastructure Fund. On behalf of the Registrant, your comments and our responses thereto are provided below. A Pre-Effective Amendment #2 to each Proxy Statement/Prospectus (the “Amendments”) was filed with the Securities and Exchange Commission on March 11, 2020.
All defined terms in this letter have the same meaning as in the Proxy Statement/Prospectus, except as otherwise defined herein.
Global Comments
Comment 1: Please clarify that it is actually the Acquired Fund that is paying the reorg costs, not the "Funds" which is defined earlier as the Acquired Fund and the Acquiring Fund (together, the “Funds”). Also, specify the rationale for Acquired Fund bearing the costs of the reorganization.
Response: We have made the requested edit.
Comment 2: Please review and revise the numbers provided in the four Expense Example tables.
Response: We have reviewed these numbers and made the necessary corrections.
Comment 3: In the Statement of Additional Information, update the net assets of the Acquired Fund to as of January 31, 2020.
Response: We have made the requested edit.
Comment 4: In the Statement of Additional Information, revise the disclosure to indicate that the Acquiring Fund has no capital loss carryforwards as of its latest fiscal year end of October 31, 2019.
Response: We have made the requested edit.
Pursuant to Rule 461 under the Securities Act of 1933 (the “Act”), the Registrant and NYLIFE Distributors LLC (“Distributor”), as general distributor of the Registrant’s shares, hereby respectfully request that the effective date of the Amendments be accelerated so that each Amendment will become effective on March 13, 2020, or as soon as practicable thereafter. The Registrant and the Distributor are aware of their obligations under the Act.
Please contact the undersigned at 201-685-6221 should you have any questions regarding this matter.
Sincerely,
/s/
Thomas C. Humbert Jr.
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CORRESP
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filename1.htm
MAINSTAY FUNDS TRUST
51 MADISON AVENUE
NEW YORK, NEW YORK 10010
VIA EDGAR CORRESPONDENCE
March 11, 2020
Mr. Mark A. Cowan
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Response to Comments on Pre-Effective Amendment #1 to the two N-14 filings (the “Proxy Statements/Prospectuses”)
for MainStay Funds Trust (the “Registrant”)
(SEC File Nos. 333-235813 and 811-22321); and (SEC File Nos
333-235812 and 811-22321)
Dear Mr. Cowan:
This letter responds to comments provided by you electronically
on March 3, 2020 and telephonically by Mr. Jason Fox on March 5, 2020 with respect to the Proxy Statements/Prospectuses. The Proxy
Statements/Prospectuses were filed with the Securities and Exchange Commission on March 2, 2020 and relate to the following proposed
mergers: (i) MainStay Cushing Renaissance Advantage Fund with and into MainStay CBRE Global Infrastructure Fund; and (ii) MainStay
Cushing Energy Income Fund with and into MainStay CBRE Global Infrastructure Fund. On behalf of the Registrant, your comments and
our responses thereto are provided below. A Pre-Effective Amendment #2 to each Proxy Statement/Prospectus (the “Amendments”)
was filed with the Securities and Exchange Commission on March 11, 2020.
All defined terms in this letter have the same meaning as in
the Proxy Statement/Prospectus, except as otherwise defined herein.
Global Comments
Comment 1: Please clarify that it is actually
the Acquired Fund that is paying the reorg costs, not the "Funds" which is defined earlier as the Acquired Fund and the
Acquiring Fund (together, the “Funds”). Also, specify the rationale for Acquired Fund bearing the costs of the reorganization.
Response: We have made the requested edit.
Comment 2: Please review and revise the numbers
provided in the four Expense Example tables.
Response: We have reviewed these numbers and made
the necessary corrections.
Comment 3: In the Statement of Additional Information,
update the net assets of the Acquired Fund to as of January 31, 2020.
Response: We have made the requested edit.
Comment 4: In the Statement of Additional Information,
revise the disclosure to indicate that the Acquiring Fund has no capital loss carryforwards as of its latest fiscal year end of
October 31, 2019.
Response: We have made the requested edit.
Pursuant
to Rule 461 under the Securities Act of 1933 (the “Act”), the Registrant and NYLIFE Distributors LLC (“Distributor”),
as general distributor of the Registrant’s shares, hereby respectfully request that the effective date of the Amendments
be accelerated so that each Amendment will become effective
on March 13, 2020, or as soon as practicable thereafter. The Registrant and the Distributor are aware of their obligations
under the Act.
Please contact the undersigned at 201-685-6221
should you have any questions regarding this matter.
Sincerely,
/s/
Thomas C. Humbert Jr.
Thomas
C. Humbert, Jr.
Assistant
Secretary
NYLIFE
Distributors LLC
/s/
Brian Wickwire
Brian
Wickwire
Chief
Operating Officer