This matter concerns multiple violations of Section 206(2) of the Advisers Act and Sections 15(c) and 34(b) of the Investment Company Act by NYLIM in connection with a mutual fund it advised, the MainStay Equity Index Fund (“Equity Index Fund”), during the period from early 2002 through June 30, 2004 (the “relevant period”). The Equity Index Fund is an open-end investment company that seeks to replicate the movements of the S&P 500 index before expenses. During the relevant period, the disinterested members of the Board of Trustees and the Board of Trustees of The MainStay Funds, approved the renewal of three investment advisory contracts between NYLIM and the Equity Index Fund. For each con...