FILE NO. 033-02610
FILE NO. 811-04550
It is proposed
that this filing will become effective immediately upon filing pursuant to Rule 462(d) under the Securities
Act of 1933, as amended.
This Post-Effective Amendment
No.167 to the Registration Statement on Form N-1A (File No. 033-02610) is being filed pursuant to Rule
462(d) under the Securities Act of 1933, as amended (the “Securities Act”), solely for the purpose
of adding exhibits to such Registration Statement. Accordingly, this Post-Effective Amendment No. 167
consists only of a facing page, this explanatory note, and Part C of the Registration Statement on Form
N-1A. This Post-Effective Amendment No. 167 does not change the form of any prospectus or Statement of
Additional Information included in post-effective amendments previously filed with the Securities and
Exchange Commission (the “SEC”). As permitted by Rule 462(d), this Post-Effective Amendment No. 167
shall become effective upon filing with the SEC.
ITEM 28. EXHIBITS
a. Declaration of
Trust
1. Declaration of Trust dated January 9, 1986, as amended and restated August 28,
2024 — Filed herewith
2. Fifth
Amended and Restated
Establishment and Designation
of Series of
Shares of Beneficial
Interest, Par Value
$.01 Per Share
dated October 26, 1992 — Previously filed as
Exhibit 1(b) to Post-Effective Amendment No. 16*
3. Establishment
and Designation of
Additional Series of
Shares of Beneficial
Interest, Par Value
$.01 Per Share
— Previously filed
as Exhibit 1(b) to Post-Effective Amendment No. 11*
4. Form
of Establishment and
Designation of Additional
Series of shares
of Beneficial Interest,
Par Value $.01
Per Share —
Previously filed as Exhibit 1(b)
to Post-Effective Amendment No. 23*
5. Form
of Establishment and
Designation of Additional
Series of Shares
of Beneficial Interest,
Par Value $.01
Per Share —
Previously filed as Exhibit 1(e)
to Post-Effective Amendment No. 28*
6. Form
of Establishment and
Designation of an
Additional Series of
Shares of Beneficial
Interest, Par Value
$.01 Per Share
— Previously filed as Exhibit
1(g) to Post-Effective Amendment No. 35 on February 26, 1997*
7. Establishment
and Designation of
an Additional Series
of Shares of
Beneficial Interest, Par
Value $.01 Per
Share — Previously
filed as Exhibit 1(h) to Post-Effective Amendment
No. 38 on August 8, 1997*
8. Establishment
and Designation of
an Additional Series of
Shares of Beneficial
Interest, Par Value
$.01 Per Share
— Previously filed
as Exhibit 1(i) to Post-Effective Amendment No. 46 on May 27, 1998*
9. Establishment
and Designations of
Class of Shares
of Beneficial Interest,
Par Value $0.01
Per Share —
Previously filed as
Exhibit (a)(10) to Post-Effective Amendment No.
51 on April 30, 1999*
10. Establishment
and Designations of
Additional Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
— Previously filed
as Exhibit (a)(11) to Post-Effective Amendment No. 51 on April 30,
1999*
11. Establishment
and Designation of
Additional Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
— Previously filed
as Exhibit (a)(11) to Post-Effective Amendment No. 55 on March 1,
2001*
12. Form
of Establishment and
Designation of Additional
Series of Shares
of Beneficial Interest,
Par Value $0.01
Per Share relating
to the Mainstay U.S. Large
Cap Equity Fund — Previously filed as Exhibit (a)(12) to Post-Effective Amendment No. 58 on December
20, 2001*
13. Establishment
and Designation of
Classes of Shares
of Beneficial Interest,
Par Value $0.01
Per Share —
Previously filed as
Exhibit (a)(13) to Post-Effective Amendment No.
65 on December 31, 2003*
14. Redesignation
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
— Previously filed
as Exhibit (a)(14)
to Post-Effective Amendment No.
65 on December 31, 2003*
15. Abolition
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 per Share
— Previously filed
as Exhibit (a)
(15) to Post-Effective
Amendment No. 65 on December 31, 2003*
16. Establishment
and Designation of
Additional Series and
Classes of Shares
of Beneficial Interest,
Par Value $0.01
Per Share —
Previously filed as Exhibit (a)(16) to Post-Effective
Amendment No. 74 on March 15, 2005*
17. Abolition
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
— Previously filed
as Exhibit (a)
(17) to Post-Effective
Amendment No. 74 on March 15, 2005*
18. Abolition
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
— Previously filed
as Exhibit (a)
(18) to Post-Effective
Amendment No. 74 on March 15, 2005*
19. Abolition
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
— Previously filed
as Exhibit (a)
(19) to Post-Effective
Amendment No. 74 on March 15, 2005*
20. Establishment
and Designation of
Additional Shares of
Beneficial Interest, Par
Value $0.01 Per
Share — Previously
filed as Exhibit
(a)(20) to Post-Effective Amendment No. 80 on April 7,
2006*
21. Establishment
and Designation of
Additional Shares of
Beneficial Interest, Par
Value $0.01 Per
Share — Previously
filed as Exhibit
1(u) to Registrant’s
Form N-14 filed with the Commission on August 10, 2007*
22. Establishment
and Designation of
Class of Shares
of Beneficial Interest,
Par Value $0.01
Per Share —
Previously filed as
Exhibit (a)(22) to
Post-Effective Amendment No. 93 on February
22, 2008*
23. Abolition
of Series of
Shares Of Beneficial
Interest, Par Value
$0.01 Per Share
(Small Cap Value)
— Previously filed
as Exhibit (a)(23)
to Post-Effective Amendment No. 106 on December
17, 2010*
24. Abolition
of Series of
Shares Of Beneficial
Interest, Par Value
$0.01 Per Share
(Institutional Bond) —
Previously filed as
Exhibit (a)(24) to
Post-Effective Amendment No. 106 on December 17, 2010*
25. Abolition
of Series of
Shares Of Beneficial
Interest, Par Value
$0.01 Per Share
(Value) — Previously
filed as Exhibit
(a)(25) to Post- Effective
Amendment No. 106 on December 17, 2010*
26. Abolition
of Series of
Shares Of Beneficial
Interest, Par Value
$0.01 Per Share
(Mid Cap Growth)
—Previously filed as
Exhibit (a)(26) to
Post-Effective Amendment No. 106 on December 17, 2010*
27. Abolition
of Series of
Shares Of Beneficial
Interest, Par Value
$0.01 Per Share
(Small Cap Growth)
— Previously filed
as Exhibit (a)(27) to Post-Effective
Amendment No. 106 on December 17, 2010*
28. Abolition
of Series of
Shares Of Beneficial
Interest, Par Value
$0.01 Per Share
(Mid Cap Value)
— Previously filed
as Exhibit (a)(28)
to Post-Effective Amendment No. 106 on December
17, 2010*
29. Abolition of
Series of
Shares Of
Beneficial Interest,
Par Value
$0.01 Per
Share (Capital
Appreciation) —
Previously filed
as Exhibit
(a)(29) to Post-Effective Amendment No. 106 on December 17, 2010*
30. Redesignation
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
(Total Return) —
Previously filed as
Exhibit (a)(30) to
Post-Effective Amendment No. 106 on December 17, 2010*
31. Redesignation
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
(Flexible Bond Opportunities)
— Previously filed
as Exhibit (a)(31) to Post-Effective Amendment No. 120 on June 17,
2013*
32. Establishment
and Designation of
Class of Shares
of Beneficial Interest,
Par Value $0.01
Per Share (Class
R3) dated December
2015 — Previously filed as Exhibit (a)(32)
to Post-Effective Amendment No. 129 on February 29, 2016*
33. Redesignation
of Series of
Shares of Beneficial
Interest, Par Value
$0.01 Per Share
(Global High Income
and MAP) —
Previously filed as Exhibit (a)(34)
to Post-Effective Amendment No. 137 on August 10, 2017*
34. Establishment
and Designation of
Class of Shares
of Beneficial Interest,
Par Value $0.01
Per Share (Class
T) — Previously
filed as Exhibit
(a)(35) to Post-Effective Amendment No. 137 on August 10, 2017*
35. Redesignation of Series of Shares of Beneficial Interest,
Par Value
$0.01 Per
Share effective
February 28,
2018 —
Previously filed
as Exhibit (a)(36) to Post-Effective Amendment No. 139 on February 28, 2018*
36. Establishment
and Designation of Class of Shares of Beneficial Interest, Par Value $0.01 Per Share (SIMPLE Class) –
Previously filed as Exhibit (a)(36) to Post-Effective Amendment No. 152 on August 31, 2020*
37. Establishment and Designation of Class of Shares of Beneficial Interest, Par Value
$0.01 Per Share (Class C2) – Previously filed as Exhibit (a)(37) to Post-Effective Amendment No. 152
on August 31, 2020*
38. Redesignation
of Series of Shares of Beneficial Interest, Par Value $0.01 Per Share effective February 28, 2020, August
31, 2020 and February 28, 2021 (Large Cap Growth, Infrastructure Bond and Unconstrained Bond) – Previously
filed as Exhibit (a)(38) to Post-Effective Amendment No. 156 on November 4, 2021*
39. Redesignation
of Series of Shares of Beneficial Interest, Par Value $0.01 Per Share effective March 5, 2021 and April
26, 2021 (Common Stock and MAP Equity) – Previously filed as Exhibit (a)(39) to Post-Effective Amendment
No. 156 on November 4, 2021*
40. Establishment
and Designation of Class Shares of Beneficial Interest, Par Value $0.01 Per Share effective March 29,
2013 – Previously filed as Exhibit (a)(40) to Post-Effective Amendment No. 161 on March 4, 2022*
b. By-Laws
1. Amended and Restated By-Laws
dated June
4, 2015
– Previously filed
as Exhibit
(b)(1) to
Post-Effective Amendment
No. 129
on February 29, 2016*
2. Amended
and Restated By-Laws dated June 24, 2020 – Previously filed as Exhibit (b)(1) to Post-Effective Amendment
No. 151 on June 26, 2020*
3. Amended
and Restated By-Laws dated August 28, 2024 – Filed herewith
c. Instruments Defining
Rights of Security Holders
1. See the
Declaration of Trust,
as amended and
supplemented from time
to time and
the Amended and
Restated By-Laws dated
June 4, 2015 (See above)
d. Investment
Advisory Contracts
1. Amended
and Restated Management
Agreement dated February
27, 2015 between
The MainStay Funds
and New York
Life Investment Management LLC
— Previously filed as Exhibit (d)(1) to Post-Effective Amendment No. 126 on February 27,
2015*
(a) Amendment
dated February 28, 2017 — Previously filed as Exhibit (d)(1)(a) to Post-Effective Amendment No. 137
on August 10, 2017*
(b) Amendment dated
February 28, 2018 — Previously filed as Exhibit (d)(1)(b) to Post-Effective Amendment No. 139 on February
28, 2018*
(c) Amendment
dated February 28,
2019 — Previously
filed as Exhibit
(d)(1)(c) to Post-Effective
Amendment No. 143
on February 15, 2019*
(d) Amendment
dated June 21,
2019 — Previously
filed as Exhibit
(d)(1)(d) to Post-Effective
Amendment No. 145
on June 21,
2019*
(e) Amendment
dated February 28, 2020 – Previously filed as Exhibit (d)(1)(e) to Post-Effective Amendment No. 149
on February 25, 2020*
(f) Amendment
dated August 31, 2020 – Previously filed as Exhibit (d)(1)(f) to Post-Effective Amendment No. 152 on
August 31, 2020*
(g) Amendment dated
February 28, 2021 – Previously filed as Exhibit (d)(1)(g) to Post-Effective Amendment No. 154 on February
24, 2021*
(h) Amendment dated
March 5, 2021 – Previously filed as Exhibit (d)(1)(h) to Post-Effective Amendment No. 156 on November
4, 2021*
(i) Amendment dated
April 26, 2021 – Previously filed as Exhibit (d)(1)(i) to Post-Effective Amendment No. 156 on November
4, 2021*
(j) Amendment dated
February 28, 2022 – Previously filed Exhibit (d)(1)(j) to Post-Effective Amendment No. 161
on March 4, 2022*
(k) Amendment
dated February 28, 2023 – Previously filed as Exhibit (d)(1)(k) to Post-Effective Amendment No. 162
on February 23, 2023*
(l) Amendment dated
September 8, 2023 – Previously filed as Exhibit (d)(1)(l) to Post-Effective Amendment No. 164 on October
25, 2023*
(m) Amendment
date February 28, 2024 – Previously filed as Exhibit (d)(1)(m) to Post-Effective Amendment No. 165
on February 26, 2024*
2. Subadvisory Agreements
(a) Amended
and Restated Sub-Advisory
Agreement between New
York Life Investment
Management LLC and
MacKay Shields LLC
dated January 1,
2018 — Previously
filed as Exhibit
(d)(2)(a) to Post-Effective
Amendment No. 139
on February 28,
2018*
i. Amendment
dated February 28,
2018 — Previously
filed as Exhibit
(d)(2)(b) to Post-Effective
Amendment No. 139
on February 28, 2018*
ii. Amendment
dated May 1, 2018 — Previously filed as Exhibit (d)(2)(a)(ii) to Post-Effective Amendment No. 141 on
October 22, 2018*
iii. Amendment
dated May 22,
2018 — Previously
filed as Exhibit
(d)(2)(a)(iii) to Post-Effective
Amendment No. 141
on October 22,
2018*
iv. Amendment
dated November 30,
2018 — Previously
filed as Exhibit
(d)(2)(a)(iv) to Post-Effective
Amendment No. 143
on February 15, 2019*
v. Amendment
dated February 28,
2019 — Previously
filed as Exhibit
(d)(2)(a)(v) to Post-Effective
Amendment No. 145
on June 21,
2019*
vi. Amendment
dated April 1,
2019 — Previously
filed as Exhibit
(d)(2)(a)(vi) to Post-Effective
Amendment No. 145
on June 21, 2019*
vii. Amendment
dated May 1,
2019 — Previously
filed as Exhibit
(d)(2)(a)(vii) to Post-Effective
Amendment No. 145
on June 21,
2019*
viii. Amendment
dated June 21,
2019 — Previously
filed as Exhibit
(d)(2)(a)(viii) to Post-Effective
Amendment No. 146
on August 21, 2019*
ix. Amendment
dated June 28, 2019 — Previously filed as Exhibit (d)(2)(a)(ix) to Post-Effective Amendment No. 146
on August 21, 2019*
x. Amendment
dated February 26, 2020 – Previously filed as Exhibit (d)(2)(a)(x) to Post-Effective Amendment No.
149 on February 25, 2020*
xi. Amendment
dated February 28, 2020 – Previously filed as Exhibit (d)(2)(a)(xi) to Post-Effective Amendment No.
149 on February 25, 2020*
xii. Amendment
dated August 31, 2020 – Previously filed as Exhibit (d)(2)(a)(xii) to Post-Effective Amendment No.
152 on August 31, 2020*
xiii. Amendment
dated February 28, 2021 – Previously filed as Exhibit (d)(2)(a)(xiii) to Post-Effective Amendment No.
155 on March 23, 2021*
xiv. Amendment
dated March 5, 2021 – Previously filed as Exhibit (d)(2)(a)(xiv) to Post-Effective Amendment No. 155
on March 23, 2021*
xv. Amendment dated
April 26, 2021 – Previously filed as Exhibit (d)(2)(a)(xv) to Post-Effective Amendment No. 156 on November
4, 2021*
xvi. Amendment dated
May 1, 2021 – Previously filed as Exhibit (d)(2)(a)(xvi) to Post-Effective Amendment No. 156 on November
4, 2021*
xvii. Amendment dated
August 28, 2021 – Previously filed as Exhibit (d)(2)(a)(xvii) to Post-Effective Amendment No. 156
on November 4, 2021*
xviii. Amendment
dated November 30, 2021 – Previously filed as Exhibit (d)(2)(a)(xviii) to Post-Effective Amendment
No. 161 on March 4, 2022*
xix. Amendment
dated February 28, 2022 –Previously filed as Exhibit (d)(2)(a)(xix) to Post-Effective Amendment No.161
on March 4, 2022*
xx. Amendment
dated May 1, 2022 – Previously filed as Exhibit (d)(2)(a)(xx) to Post-Effective Amendment No. 164 on
October 25, 2023*
xxi. Amendment
dated August 28, 2023 – Previously filed as Exhibit (d)(2)(a)(xxi) to Post-Effective Amendment No.
164 on October 25, 2023*
xxii. Amendment
dated September 8, 2023 – Previously filed as Exhibit (d)(2)(a)(xxii) to Post-Effective Amendment No.
164 on October 25, 2023*
xxiii. Amendment
dated February 28, 2024 – Previously filed as Exhibit (d)(2)(a)(xxiii) to Post-Effective Amendment
No. 165 on February 26, 2024*
xxiv. Amendment
dated May 1, 2024 – Previously filed as Exhibit (d)(2)(a)(xxiv) to Post-Effective Amendment No. 166
on February 25, 2025*
xxv. Amendment
dated May 27, 2024 – Previously filed as Exhibit (d)(2)(a)(xxv) to Post-Effective Amendment No. 166
on February 25, 2025*
xxvi. Amendment
dated February 28, 2025 – Previously filed as Exhibit (d)(2)(a)(xxvi) to Post-Effective Amendment No.
166 on February 25, 2025*
xxvii. Amendment
dated February 28, 2025 – Previously filed as Exhibit (d)(2)(a)(xxvii) to Post-Effective Amendment
No. 166 on February 25, 2025*
(b) Subadvisory
Agreement between New
York Life Investment
Management LLC and
Winslow Capital Management,
Inc. dated October
1, 2014 — Previously filed as Exhibit (d)(2)(b) to Post- Effective Amendment
No. 126 on February 27, 2015*
i. Amendment dated
February 28,
2016 —
Previously filed
as Exhibit
(d)(2)(b)(i) to
Post-Effective Amendment
No. 129
on February 29, 2016*
ii. Amendment dated February 28, 2020 – Previously filed as Exhibit (d)(2)(b)(ii)
to Post-Effective Amendment No. 149 on February 25, 2020*
(c) Subadvisory
Agreement between New
York Life Investment
Management LLC and
Epoch Investment Partners,
Inc. dated March
31, 2017 — Previously filed as Exhibit (d)(2)
to MainStay Funds Trust’s Post-Effective Amendment No. 115 on August 10, 2017*
i. Amendment
dated May 8,
2017 — Previously
filed as Exhibit
(d)(2)(a) to MainStay
Funds Trust’s Post-Effective
Amendment No. 115 on August 10,
2017*
ii. Amendment
dated February 28,
2019 — Previously
filed as Exhibit
(d)(2)(c)(ii) to Post-Effective
Amendment No. 145
on June 21,
2019*
iii. Amendment
dated April 1,
2019 — Previously
filed as Exhibit
(d)(2)(c)(iii) to Post-Effective
Amendment No. 145
on June 21,
2019*
iv. Amendment
dated May 1,
2019 — Previously
filed as Exhibit
(d)(2)(c)(iv) to Post-Effective
Amendment No. 145
on June 21, 2019*
v. Amendment dated
April 26, 2021 – Previously filed as Exhibit (d)(2)(c)(v) to Post-Effective Amendment No. 164 on October
25, 2023*
(d) Subadvisory Agreement
dated May 1, 2014 between New York Life Investment Management LLC and NYL Investors LLC —Previously
filed as Exhibit
(d)(2)(h) to Post-Effective
Amendment No. 131
on September 12,
2016*
i. Amendment dated
February 28, 2017 — Previously filed as Exhibit (d)(2)(h)(i) to Post-Effective Amendment No. 137 on
August 10, 2017*
(e) Amended and Restated Subadvisory Agreement
between New York Life Investment Management LLC and Candriam dated July 1, 2022 – Filed herewith
(f) Subadvisory
Agreement between New York Life Investment Management LLC and Wellington Management Company LLC dated
March 5, 2021 – Previously filed as Exhibit (d)(2)(g) to Post-Effective Amendment No. 155 on March
23, 2021*
i. Amendment dated
May 1, 2023 – Previously filed as Exhibit (d)(2)(f)(i) to Post-Effective Amendment No. 164 on
October 25, 2023*
ii. Amendment
dated August 12, 2024 – Previously filed as Exhibit (d)(2)(f)(ii) to Post Effective Amendment No. 166
on February 25, 2025*
e. Underwriting Contracts
1. Amended and Restated
Master Distribution Agreement between the MainStay Funds and NYLIFE Distributors Inc. dated August 1,
2014 —
Previously filed as
Exhibit (e)(1) to
Post-Effective Amendment No.
126 on February
27, 2015*
2. Form of Soliciting
Dealer Agreement — Previously filed as Exhibit (e)(2) to Post-Effective Amendment No. 129 on February
29, 2016*
f. Bonus or Profit Sharing Contracts — Inapplicable
g. Custodian
Agreements
1. Global Custody Agreement with JPMorgan Chase Bank, National Association dated
June 22, 2020 – Previously filed as Exhibit (g)(3) to Post-Effective Amendment No. 155 on March 23,
2021*
(a) Amendment dated May 1, 2021 – Previously filed as Exhibit (g)(1)(a) to Post-Effective
Amendment No. 156 on November 4, 2021*
(b) Amendment dated September 9, 2021 – Previously filed as Exhibit (g)(1)(b) to
Post-Effective Amendment No. 156 on November 4, 2021*
(c) Amendment
dated March 30, 2023 – Previously filed as Exhibit (g)(1)(c) to Post-Effective Amendment No. 164 on
October 25, 2023*
(d) Amendment
dated May 16, 2023 – Previously filed as Exhibit (g)(1)(d) to Post-Effective Amendment No. 164 on October
25, 2023*
(e) Amendment
dated January 3, 2024 – Previously filed as Exhibit (g)(1)(e) to Post-Effective Amendment No. 166 on
February 25, 2025*
(f) Amendment
dated April 9, 2024 – Previously filed as Exhibit (g)(1)(f) to Post-Effective Amendment No. 166 on
February 25, 2025*
(g) Amendment
dated July 5, 2024 – Previously filed as Exhibit (g)(1)(g) to Post-Effective Amendment No. 166 on February
25, 2025*
(h) Amendment
dated September 5, 2024 – Previously filed as Exhibit (g)(1)(h) to Post-Effective Amendment No. 166
on February 25, 2025*
(i) Amendment
dated December 18, 2024 – Previously filed as Exhibit (g)(1)(i) to Post-Effective Amendment No. 166
on February 25, 2025*
h. Other Material Contracts
1. Transfer
Agency
(a) Amended
and Restated Transfer
Agency and Service
Agreement dated October
1, 2008 —
Previously filed as
Exhibit h (1)(a)
to Post-Effective Amendment
No. 96 on November 25, 2008*
i. Amendment
dated April 24,
2009 — Previously
filed as Exhibit
(h)(1)(a)(i) to Post-Effective
Amendment No. 107
on February 28, 2011*
ii. Amendment
dated October 16,
2009 — Previously
filed as Exhibit
(h)(1)(a)(ii) to Post-Effective
Amendment No. 107
on February 28, 2011*
iii. Amendment
dated October 23,
2009 — Previously
filed as Exhibit
(h)(1)(a)(iii) to Post-Effective
Amendment No. 107
on February 28, 2011*
iv. Amendment
dated October 30,
2009 — Previously
filed as Exhibit
(h)(1)(a)(iv) to Post-Effective
Amendment No. 107
on February 28, 2011*
v. Amendment
dated November 12,
2009 — Previously
filed as Exhibit
(h)(1)(a)(i) to MainStay
Funds Trust’s Post-Effective
Amendment No. 9 on February 28, 2011*
vi. Amendment
dated November 24,
2009 — Previously
filed as Exhibit
(h)(1)(a)(ii) to MainStay
Funds Trust’s Post-Effective
Amendment No. 9 on February 28, 2011*
vii. Amendment dated
February 26, 2010 — Previously filed as Exhibit (h)(1)(a)(iii) to MainStay Funds Trust’s
Post-Effective Amendment No. 9 on February 28,
2011*
viii. Amendment
dated March 30,
2010 — Previously
filed as Exhibit
(h)(1)(a)(iv) to MainStay
Funds Trust’s Post-Effective
Amendment No. 9 on February 28, 2011*
ix. Amendment
dated January 1,
2011 — Previously
filed as Exhibit
(h)(1)(a)(v) to MainStay
Funds Trust’s Post-Effective
Amendment No. 9 on February 28, 2011*
x. Amendment
dated January 1,
2012 — Previously
filed as Exhibit
(h)(1)(a)(vi) to MainStay
Funds Trust’s Post-Effective
Amendment No. 40 on February 27, 2013*
xi. Amendment
dated January 1,
2013 — Previously
filed as Exhibit
(h)(1)(a)(x) to Post-Effective
Amendment No. 120
on June 17,
2013*
xii. Amendment
dated July 11,
2014 — Previously
filed as Exhibit
(h)(1)(a)(xii) to Post-Effective
Amendment No. 126
on February 27, 2015*
xiii. Amendment
dated February 29,
2016 — Previously
filed as Exhibit
(h)(1)(a)(xiii) to Post-Effective
Amendment No. 129
on February 29, 2016*
xiv. Amendment
dated June 30,
2016 — Previously
filed as Exhibit
(h)(1)(a)(xi) to Post-Effective
Amendment No. 100
to MainStay Funds Trust’s Registration Statement
on September 12, 2016*
xv. Amendment
dated March 13,
2017 — Previously
filed as Exhibit
(h)(1)(a)(xii) to MainStay
Funds Trust’s Post-Effective
Amendment No. 115 on August 10, 2017*
xvi. Amendment
dated April 11,
2017 — Previously
filed as Exhibit
(h)(1)(a)(xiii) to MainStay
Funds Trust’s Post-Effective
Amendment No. 115 on August 10, 2017*
xvii. Amendment
dated May 8,
2017 — Previously
filed as Exhibit
(h)(1)(a)(xiv) to MainStay
Funds Trust’s Post-Effective
Amendment No. 115 on August 10, 2017*
xviii. Amendment
dated November 15, 2017 – Previously filed as Exhibit (h)(1)(a)(xviii) to Post-Effective Amendment
No. 139 on February 28, 2018*
xix. Amendment
dated February 28,
2018 – Previously
filed as Exhibit
(h)(1)(a)(xix) to Post-Effective
Amendment No. 139
on February 28, 2018*
xx. Amendment
dated May 22, 2018 – Previously filed as Exhibit (h)(1)(a)(xx) to Post-Effective Amendment No. 141
on October 22,
2018*
xxi. Amendment
dated July 2,
2018 – Previously
filed as Exhibit
(h)(1)(a)(xxi) to Post-Effective
Amendment No. 141
on October 22,
2018*
xxii. Amendment
dated November 30,
2018 – Previously
filed as Exhibit
(h)(1)(a)(xxii) to Post-Effective
Amendment No. 143
on February 15, 2019*
xxiii. Amendment
dated February 28,
2019 – Previously
filed as Exhibit
(h)(1)(a)(xxiii) to
Post-Effective Amendment No.
143 on February 15,
2019*
xxiv. Amendment
dated April 1,
2019 – Previously
filed as Exhibit
(h)(1)(a)(xxiv) to Post-Effective
Amendment No. 145
on June 21, 2019*
xxv. Amendment
dated June 14,
2019 – Previously
filed as Exhibit
(h)(1)(a)(xxv) to Post-Effective
Amendment No. 145
on June 21, 2019*
xxvi. Amendment dated November 1, 2019 – Previously filed as Exhibit (h)(1)(a)(xxvi)
to Post-Effective Amendment No. 148 on December 18, 2019*
xxvii. Amendment dated February 26, 2020 – Previously filed as Exhibit (h)(1)(xxvii)
to Post-Effective Amendment No. 149 on February 25, 2020*
xxviii. Amendment
dated May 1, 2020 – Previously filed as Exhibit (h)(1)(xxviii) to Post-Effective
Amendment No. 151 on June 26, 2020*
xxix. Amendment
dated May 22, 2020 – Previously filed as Exhibit (h)(1)(xxix) to Post-Effective Amendment No. 151 on
June 26, 2020*
xxx. Amendment dated June 30, 2020 – Previously filed as Exhibit (h)(1)(xxx) to Post-Effective
Amendment No. 151 on June 26, 2020*
xxxi. Amendment
dated September 30, 2020 – Previously filed as Exhibit (h)(1)(xxxi) to Post-Effective Amendment No.
154 on February 24, 2021*
xxxii. Amendment dated February 28, 2021 – Previously filed as Exhibit (h)(1)(xxxii)
to Post-Effective Amendment No. 154 on February 24, 2021*
xxxiii. Amendment
dated September 30, 2021 – Previously filed as Exhibit (h)(1)(xxxiii) to Post-Effective Amendment No.
156 on November 4, 2021*
xxxiv. Amendment
dated October 26, 2021 – Previously filed as Exhibit (h)(1)(xxxiv) to Post-Effective Amendment No.
156 on November 4, 2021*
xxxv. Amendment dated February 28, 2022 – Previously filed as Exhibit (h)(1)(xxxv)
to Post-Effective Amendment No. 161 on March 4, 2022*
xxxvi. Amendment
dated January 1, 2023 – Previously filed as Exhibit (h)(1(xxxvi) to Post-Effective Amendment No. 162
on February 23, 2023
xxxvii. Amendment
dated July 24, 2023 – Previously filed as Exhibit (h)(1)(xxxvii) to Post-Effective Amendment No. 164
on October 25, 2023*
xxxviii. Amendment
dated August 28, 2023 – Previously filed as Exhibit (h)(1)(xxxviii) to Post-Effective Amendment No.
164 on October 25, 2023*
xxxix. Amendment
dated February 28, 2024 – Previously filed as Exhibit (h)(1)(xxxix) to Post-Effective Amendment No.
165 on February 26, 2024*
xl. Amendment
dated July 1, 2024 – Previously filed as Exhibit (h)(1)(xl) to Post-Effective Amendment No. 166 on
February 25, 2025*
xli. Amendment dated
July 22, 2024 – Previously filed as Exhibit (h)(1)(xli) to Post-Effective Amendment No. 166 on February
25, 2025*
xlii. Amendment dated July 1, 2025 – Filed herewith
2. Amended
and Restated Service
Agreement with New
York Life Benefit
Services, Inc. —
Previously filed as
Exhibit (h)(3) to
Post- Effective Amendment No. 80 on April 7,
2006*
3. Amended and Restated
Shareholder Services Plan for Class R1 Shares dated June 4, 2024 — Previously filed as Exhibit (h)(1)(3)
to Post-Effective Amendment No. 166 on February 25, 2025*
4. Amended and Restated
Shareholder Services Plan for Class R2 Shares dated June 4, 2024 — Previously filed as Exhibit (h)(1)(4)
to Post-Effective Amendment No. 166 on February 25, 2025*
5. Amended and Restated
Shareholder Services Plan for Class R3 Shares dated June 4, 2024 — Previously filed as Exhibit (h)(1)(5)
to Post-Effective Amendment No. 166 on February 25, 2025*
6. Form of Indemnification
Agreement — Previously filed as Exhibit (h)(10) to Post-Effective Amendment No. 80 on April 7,
2006*
7. Expense
Limitation Agreements and Fee Waivers
(a) Notice of Fee Waiver
(Contractual — Winslow Large Cap Growth Fund) dated February 29, 2020 – Previously filed as Exhibit
(h)(7)(b) to Post-Effective Amendment No. 149 on February 25, 2020*
(b) Notice of Voluntary
Expense Limitation Agreement dated February 28, 2024 – Previously filed as Exhibit (h)(7)(b) to Post-Effective
Amendment No. 165 on February 26, 2024*
(c) Amended
and Restated Expense Limitation Agreement (Transfer Agency) dated May 27, 2024 – Previously filed as
Exhibit (h)(7)(c) to Post-Effective Amendment No. 166 on February 25, 2025*
(d) Amended and Restated Expense Limitation Agreement dated August
28, 2025 – Filed herewith
8. Regulatory Filing Support Services Agreement dated December 22, 2017 — Previously
filed as Exhibit (h)(8) to Post-Effective Amendment No. 139 on February 28, 2018*
9. Form of MainStay
Funds 12d1-4 Agreement – Previously filed as Exhibit (h)(9) to Post-Effective Amendment No. 161 on
March 4, 2022*
i. Legal
Opinion
1. Opinion
and consent of counsel – Not applicable
j. Other Opinions
1. Consent of Independent Registered Public Accounting Firm –
Not applicable
2. Powers of Attorney
— Previously filed as Exhibits to Post-Effective Amendment No. 106 on December
17, 2010*
3. Powers
of Attorney (Blunt,
Chow and Perold)
— Previously filed
as Exhibits to
Post-Effective Amendment No.
129 on February
29, 2016*
4. Power
of Attorney (Hung) — Previously filed as an Exhibit to Post-Effective Amendment No. 135 on February
28, 2017*
5. Power
of Attorney (Lehneis) —Previously filed as an Exhibit to Post-Effective Amendment No. 138 on December
22, 2017*
6. Power
of Attorney (Hammond) – Previously filed as an Exhibit to Post-Effective Amendment No. 157 on January
10, 2022
7. Power
of Attorney (Abou-Jaoudé) – Previously filed as Exhibit (j)(7) to Post-Effective Amendment No. 164
on October 25, 2023*
k. Omitted
Financial Statements — Inapplicable
l. Initial Capital
Agreements — Inapplicable
m. Rule 12b-1 Plan
1. Amended and Restated
Plan of Distribution pursuant to Rule 12b-1 (Class A shares) — Previously filed as Exhibit (m)(1) to
Post-Effective Amendment No. 146 on August 21,
2019*
2. Amended
and Restated Plan
of Distribution pursuant
to Rule 12b-1
(Class B shares)
— Previously filed
as Exhibit (m)(2)
to Post-Effective Amendment No. 146
on August 21, 2019*
3. Amended
and Restated Plan
of Distribution pursuant
to Rule 12b-1
(Class C shares)
— Previously filed
as Exhibit (m)(3)
to Post-Effective Amendment No. 146
on August 21, 2019*
4. Plan
of Distribution pursuant
to Rule 12b-1
(Class R2 shares)
— Previously filed
as Exhibit (m)(4)
to Post-Effective Amendment
No. 146 on August 21,
2019*
5. Plan
of Distribution pursuant
to Rule 12b-1
(Class R3 shares)
— Previously filed
as Exhibit (m)(5)
to Post-Effective Amendment
No. 146 on August 21,
2019*
6. Plan of Distribution pursuant to Rule 12b-1 (Investor Class shares) — Previously
filed as Exhibit (m)(6) to Post-Effective Amendment No.
146 on August 21, 2019*
7. Plan of Distribution Pursuant to Rule 12b-1 (Class C2 shares)
dated June 24, 2020 – Filed herewith
8. Plan
of Distribution Pursuant to Rule 12b-1 (SIMPLE Class shares) dated June 24, 2020 – Previously filed
as Exhibit (m)(8) to Post-Effective Amendment No. 152 on August 31, 2020*
n. Rule 18f-3 Plan
1. Amended and Restated
Multiple Class Plan Pursuant to Rule 18f-3 dated March 4, 2024 – Previously filed as Exhibit (n)(1)
to Post-Effective Amendment No. 166 on February 25, 2025*
o. Reserved
p. Codes
of Ethics
1. Code
of Ethics of New York Life Investments dated December 2024 – Filed herewith
2. Code
of Ethics of Candriam dated October 2024 – Filed herewith
3. Code of Ethics
of Nuveen Investments Inc. dated February 2023 – Previously filed as Exhibit (p)(4) to Post-Effective
Amendment No. 165 on February 26, 2024*
4. Code
of Ethics of Epoch Investment Partners, Inc. dated October 2024 – Filed herewith
5. Code of Ethics
of Wellington Management Company LLC dated December 2023 – Previously filed as Exhibit (p)(6) to Post-Effective
Amendment No. 165 on February 26, 2024
______________________
* Incorporated herein by reference.
ITEM 29. PERSONS CONTROLLED BY OR UNDER COMMON CONTROL WITH REGISTRANT
None.
ITEM 30. INDEMNIFICATION
The
New York Life Investments Group
of Funds, which
includes New York Life Investments Funds
Trust, New York Life Investments VP
Funds Trust and
New York Life Investments Funds,
maintains a joint
directors and officers/errors and omissions (“D&O/E&O”) liability
insurance policy and joint independent directors liability (“IDL”) insurance
policy. The D&O/E&O
liability insurance policy
covers all of
the directors and
officers of the
New York Life Investments Group
of Funds and
the IDL insurance
policy covers the
independent directors only.
Subject to the
terms, conditions and
retentions of the
policies, insured persons
are covered for
claims made against them while acting in their
official capacities with the New York Life Investments Group of Funds.
Article IV of New York Life Investments Funds’ (“Registrant’s”)
Declaration of Trust states as follows: Section 4.3. Mandatory
Indemnification.
(a) Subject to the exceptions and limitations contained in paragraph
(b) below:
(i) every person who is, or has been, a Trustee or officer of
the Trust shall be indemnified by the Trust, or by one or more
Series thereof if
the claim arises
from his or
her conduct with
respect to only
such Series, to
the fullest extent
permitted by law
against all liability
and against all expenses reasonably incurred or paid by him in connection with
any claim, action, suit or proceeding in which he becomes involved
as a party
or otherwise by
virtue of his
being or having
been a Trustee
or officer and
against amounts paid
or incurred by
him in the
settlement thereof;
(ii) the words “claim,” “action,” “suit,” or “proceeding”
shall apply to all claims, actions, suits or proceedings (civil,
criminal, or other,
including appeals), actual
or threatened; and
the words “liability”
and “expenses” shall
include, without limitation,
attorneys ‘ fees, costs, judgments, amounts paid
in settlement, fines, penalties and other liabilities.
(b) No
indemnification shall be provided hereunder to a Trustee or officer:
(i) against
any liability to
the Trust or
a Series thereof
or the Shareholders
by reason of
a final adjudication
by a court
or other body before
which a proceeding
was brought that
he engaged in
willful misfeasance, bad
faith, gross negligence
or reckless disregard
of the duties involved
in the conduct of his office:
(ii) with respect
to any matter
as to which
he shall have
been finally adjudicated
not to have
acted in good
faith in the
reasonable belief that his action was in the best interest of the Trust or a Series
thereof:
(iii) in
the event of a settlement or other disposition not involving a final adjudication as provided in paragraph
(b)(i) or (b)
(ii) resulting
in a payment
by a Trustee
or officer, unless
there has been
a determination that
such Trustee or
officer did not
engage in willful
misfeasance, bad faith, gross negligence or reckless disregard of the duties involved
in the conduct of his office:
(A) by the court or
other body approving the settlement or other disposition; or
(B) based
upon a review of readily available facts (as opposed to a full trial-type inquiry) by (x) vote of
a majority of
the Non-interested Trustees
acting on the
matter (provided that
a majority of
the Non-interested Trustees
then in office
act on the matter) or (y) written opinion of independent legal counsel.
(c) The
rights of indemnification
herein provided may
be insured against
by policies maintained
by the Trust,
shall be severable,
shall not affect
any other rights
to which any
Trustee or officer
may now or
hereafter be entitled,
shall continue as
to a person
who has ceased
to be such
Trustee or officer
and shall inure
to the benefit
of the heirs,
executors, administrators and
assigns of such
a person. Nothing
contained herein shall affect any
rights to indemnification to which personnel of the Trust other than Trustees and officers may be entitled
by contract or otherwise under law.
(d) Expenses
of preparation and presentation of a defense to any claim, actions suit or proceeding of the character
described in paragraph (a)
of this Section
4.3 may be
advanced by the
Trust or a Series
thereof prior to
final disposition thereof
upon receipt of
an undertaking by
or on behalf of the recipient to repay such amount if it is ultimately determined
that he is not entitled to indemnification under this Section 4.3, provided that
either:
(i) such undertaking is secured by a surety bond or some other
appropriate security provided by the recipient, or the Trust or Series
thereof shall be insured against losses arising out of any such advances; or
(ii) a
majority of the
Non-interested Trustees acting
on the matter
(provided that a majority
of the Non-interested
Trustees act on the
matter) or an
independent legal counsel
in a written
opinion shall determine,
based upon a review
of readily available
facts (as opposed
to a full trial-type inquiry), that there
is reason to believe that the recipient ultimately will be found entitled to indemnification.
As used in
this Section 4.3, a “Non-interested
Trustee” is one
who is not
(i) an “Interested
Person” of the Trust
(including anyone who
has been exempted from being
an “Interested Person” by any rule, regulation or order of the Commission), or (ii) involved in the
claim, action, suit or proceeding.
In addition, each
Trustee has entered into a written agreement with the Trust pursuant to which the Trust is contractually
obligated to indemnify the Trustees to the
fullest extent permitted by law and by the Declaration of Trust and Bylaws of the Trust.
Insofar as indemnification
for liability arising
under the Securities
Act of 1933
may be permitted
to trustees, officers
and controlling persons
of the Registrant pursuant
to the foregoing provisions, or otherwise, the Registrant has been advised that in the opinion of the
Securities and Exchange Commission such
indemnification is against public policy as expressed in the Act and is, therefore, unenforceable. In
the event that a claim for indemnification against such liabilities
(other than the payment by the Registrant of expenses incurred or paid by a trustee, officer or
controlling person of
the Registrant in
the successful defense of
any action, suit
or proceeding) is
asserted by such
trustee, officer or
controlling person in
connection with the securities being registered, the Registrant will, unless in
the opinion of its counsel the matter has been settled by controlling
precedent, submit to
a court of
appropriate jurisdiction the
question whether such
indemnification by it
is against public
policy as expressed
in the Act
and will be
governed by the
final adjudication of
such issue.
ITEM
31. BUSINESS OR OTHER CONNECTIONS OF INVESTMENT ADVISOR
New
York Life Investment
Management LLC (“New
York Life Investments”)
acts as the
investment adviser for
each series of
the following open-
end registered management
investment companies: New York Life Investments
Funds Trust, New York Life Investments
VP Funds Trust
and New York Life Investments Funds.
The list of officers and directors of New York Life Investments, together with
information as to their other business, profession, vocation or
employment of a substantial
nature during the
past two years,
is incorporated by
reference to Schedules A
and D of
Form ADV filed
by New York
Life Investments (SEC File No: 801-57396).
CANDRIAM
Candriam acts as the subadvisor for certain
series of the Registrant.
The
list of officers
and directors of
Candriam, together with
information as to
their other business,
profession, vocation or employment
of a substantial
nature during the
past two years,
is incorporated by
reference to Schedules A
and D of
Form ADV filed
by Epoch (SEC
File No: 801-80510).
EPOCH
INVESTMENT PARTNERS, INC.
Epoch
Investment Partners, Inc.
(“Epoch”) acts as
the subadvisor for
certain series of
the Registrant.
The
list of officers
and directors of
Epoch, together with
information as to
their other business,
profession, vocation or
employment of a substantial
nature during the past two years, is incorporated by reference to Schedules A
and D of Form ADV filed by Epoch (SEC File No: 801-63118).
MACKAY SHIELDS LLC
MacKay
Shields LLC (“MacKay Shields”) acts as the subadvisor for certain series of the Registrant.
The list of
officers and directors
of MacKay Shields, together
with information as
to their other
business, profession, vocation
or employment of
a substantial nature
during the past
two years, is
incorporated by reference
to Schedules A and
D of Form
ADV filed by
MacKay Shields (SEC
File No: 801-5594).
NYL INVESTORS LLC
NYL
Investors LLC (“NYL
Investors “) acts
as the subadvisor
for certain series
of the Registrant.
The list of officers and directors of NYL Investors, together with information
as to their other business, profession, vocation or employment of a substantial
nature during the
past two years,
is incorporated by
reference to Schedules
A and D of
Form ADV filed
by NYL Investors
(SEC File No: 801-78759).
WELLINGTON MANAGEMENT COMPANY LLC
Wellington
Management Company LLC (“Wellington”) acts as the subadvisor for certain series of the Registrant.
The list of officers and directors of Wellington, together
with information as to their other business, profession, vocation or employment of a substantial nature
during the past two years, is incorporated by reference to Schedules A and D of Form ADV filed by Wellington
(SEC File No: 801-15908).
WINSLOW CAPITAL MANAGEMENT INC.
Winslow Capital Management
Inc. (“Winslow Capital”)
acts as the
subadvisor for certain
series of the
Registrant.
The list of officers and directors of Winslow
Capital, together with information as to their other business, profession, vocation or employment of
a substantial nature
during the past
two years, is
incorporated by reference
to Schedules A and
D of Form
ADV filed by
Winslow Capital (SEC
File No: 801-41316) .
ITEM 32. PRINCIPAL UNDERWRITERS
a. Inapplicable
b. Inapplicable
c. Inapplicable
ITEM 33. LOCATION OF ACCOUNTS
AND RECORDS.
Certain accounts, books and other documents required to be
maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and
the rules promulgated
thereunder are maintained
at the offices
of New York
Life Insurance Company,
51 Madison Avenue,
New York, NY
10010; New York
Life Investment Management
LLC, 30 Hudson
Street, Jersey City,
NJ 07302; Candriam
(formerly Candriam Luxembourg S.C.A.), 19-21 route
d’Arlon L-8009 Strassen Luxembourg; Epoch Investment Partners, Inc., 1 Vanderbilt
Avenue, New York, NY 10017; MacKay Shields LLC, 299 Park Avenue, 32nd
Floor, New York,
NY 10171; Wellington Management
Company LLC, 280 Congress Street, Boston, MA 02210; and Winslow
Capital Management, LLC, 4400 IDS Center, 80 South
Eighth Street, Minneapolis,
Minnesota 55402. Records relating to the duties of the custodian
for each series of New York Life Investments Funds are maintained by JPMorgan Chase Bank, N.A., 383 Madison
Avenue, New York, New York 10179. Records relating to the duties of the transfer agent of New York Life
Investments Funds are maintained by DST Asset Manager Solutions, Inc., 200 Crown Colony Drive, Quincy,
MA 02169.
ITEM 34. MANAGEMENT SERVICES.
Inapplicable.
ITEM 35. UNDERTAKINGS.
Inapplicable.
SIGNATURES
Pursuant to
the requirements of
the Securities Act
of 1933 and
the Investment Company
Act of 1940,
the Registrant certifies that it meets all of the requirements for effectiveness
of this Registration Statement under Rule 485(b) and that has duly
caused this Post-Effective Amendment No. 167 to
its Registration Statement to be signed on its behalf by the undersigned, thereunto duly authorized,
in the City of New York
in the State of New York, on the 19th day of September, 2025.
| | |
| NEW YORK LIFE INVESTMENTS FUNDS |
| | |
| By: | /s/ Kirk C. Lehneis |
| | Kirk C. Lehneis |
| | President and Principal Executive Officer |
Pursuant
to the requirements of the Securities Act of 1933, this Post-Effective Amendment No. 167 to the Registration
Statement has been signed below by the following persons in the capacities indicated on September 19,
2025.
| | |
SIGNATURE | TITLE |
| |
| |
/s/ Kirk C. Lehneis | President and Principal Executive Officer |
Kirk C. Lehneis | |
| |
/s/ Naïm Abou-Jaoudé* | Trustee |
Naïm Abou-Jaoudé | |
| |
/s/ Susan B. Kerley* | Trustee |
Susan B. Kerley | |
| |
/s/ David H. Chow* | Trustee |
David H. Chow | |
| |
/s/ Karen Hammond* | Trustee |
Karen Hammond | |
| |
/s/ Alan R. Latshaw* | Trustee |
Alan R. Latshaw | |
| |
/s/ Jacques P. Perold* | Trustee and Chairman of the Board |
Jacques P. Perold | |
| |
/s/ Richard S. Trutanic* | Trustee |
Richard S. Trutanic | |
| |
/s/ Jack R. Benintende | Treasurer and Principal Financial and Accounting Officer |
Jack R. Benintende | |
| |
By:
| /s/ J. Kevin Gao | |
| J. Kevin Gao | Secretary |
| As
Attorney-in-Fact | |
| |
* Pursuant to Powers of Attorney previously
filed | |
| |
Exhibit Index
Exhibit
(a)(1) Declaration
of Trust dated January 9, 1986, as amended and restated August 28, 2024
(b)(3) Amended
and Restated By-Laws dated August 28, 2024
(d)(2)(e) Amended and Restated Subadvisory Agreement between New York
Life Investment Management LLC and Candriam dated July 1, 2022
(h)(1)(a)(xlii) Amendment
dated July 1, 2025, to the Transfer Agency Agreement
(h)(7(d) Amended and Restated Expense Limitation Agreement dated August
28, 2025
(m)(7) Plan of Distribution Pursuant to Rule 12b-1 dated June 24,
2020 for Class C2 Shares
(p)(1) Code of Ethics of New York Life Investments dated December
2024
(p)(2) Code of Ethics of Candriam dated October 2024
(p)(4) Code
of Ethics of Epoch Investment Partners, Inc. dated October 2024