Year-end 2007 Conflicts of Interest-Compliance Questionnaire



New York Life Insurance Company

Year-end 2007 Conflicts of Interest/Compliance Questionnaire

Name: Title:

(Please Print)

Dept./Location: Telephone Number:

The purpose of this questionnaire is to obtain required information from officers and certain other employees (collectively, “employees”) of New York Life Insurance Company and its subsidiaries and joint ventures (collectively, the “Company” or “New York Life”) regarding any actual or potential conflicts of interest between the employee and the Company or its customers or suppliers, and compliance with certain domestic and foreign laws, rules and regulations. The relevant policies to which all employees are subject are contained in Integrity - Standards of Business Conduct (“Integrity”)(which can be found on the New York Life Intranet) (About New York Life/Policies/Business Conduct/Integrity Manual). Integrity should be consulted for specific information regarding the questions that follow. If you need a copy of Integrity or if you have any questions, please call John O’Byrne at (212) 576-6556.

In addition to Integrity, employees of New York Life subsidiaries and joint ventures are required to adhere to any additional Codes of Ethics or policies that have been adopted by that subsidiary or joint venture.

If the answer to any of the following questions is “yes,” please provide complete and specific details on pages 7 or 8, identifying the question by number. Information must be provided on this questionnaire even if it has been previously disclosed to the Committee on Conflicts of Interest. If any information was omitted from a prior questionnaire, it should also be provided.

Please note that you are under a continuing obligation to notify the Committee on Conflicts of Interest of any changes to any response that would result in a different answer to any question(s) below. To notify the Committee, please contact John O’Byrne at (212) 576-6556.

UNLESS OTHERWISE INDICATED, THE INFORMATION REQUESTED COVERS THE CALENDAR YEAR ENDED DECEMBER 31, 2007.

|Affiliations with Business Entities – Include both for-profit and not-for-profit affiliations. Exclude affiliations with New York Life subsidiaries and joint ventures.|

| | |Yes |No |

|1. |During the calendar year ended December 31, 2007, have you been affiliated with any enterprise as an officer, director, (or member of a | | |

| |committee of a Board of Directors), manager, trustee, partner, employee, independent contractor or sole proprietor? | | |

(Please provide complete details of any “yes” answer on Page 7.)

|Financial Interests in Business Entities – Exclude affiliations with New York Life subsidiaries and joint ventures. |

|2. |During the calendar year ended on December 31, 2007, have you, or to the best of your knowledge, has any member of your family,[1] been employed by, licensed |

| |with, served as an officer, director (or member of a committee of a Board of Directors), manager or trustee of, or owned or held, directly or indirectly, a |

| |Significant Interest[2] in any of the following: |

| | | |Yes |No |

| |a. |A business entity that, to your knowledge, is a provider of goods and/or services to the Company (e.g., PricewaterhouseCoopers or | | |

| | |Staples)? | | |

| |b. |A business entity that, to your knowledge, engages in commercial or financial transactions with the Company other than as a provider| | |

| | |of goods and services? | | |

| |c. |A business entity in which, to your knowledge, the Company holds a financial or other interest? | | |

| |d. |A company whose principal business is the issue and sale of insurance or annuities? | | |

| |e. |An insurance agency, brokerage or insurance consulting firm, or a mortgage banking concern? | | |

| |f. |A business entity that, to your knowledge, is a mortgage loan correspondent of the Company? | | |

| |g. |An investment bank, investment company, investment advisor, broker-dealer, or other firm engaged in the business of buying and | | |

| | |selling securities or providing investment advice? | | |

| |h. |An organization that provides legal, accounting, consulting, training, or management services to the financial services industry? | | |

| |i. |A business entity that, to your knowledge, has property subject to a real estate mortgage held by the Company? | | |

(Please provide complete details of any “yes” answer on page 8)

|Other Financial Interests and Transactions |

|3 |Have you (or do you) or, to the best of your knowledge, has (or does) any member of your family1: |

| | |Yes |No |

| |a. |Held a financial or other interest (not disclosed elsewhere in this questionnaire) that affects or conflicts with or might appear to| | |

| | |affect or conflict with the interests of the Company or the discharge of your duties and responsibilities to the Company? | | |

| |b. |Been involved in any transaction, proposed, or consummated, to which the Company is a party and in which you or any member of your | | |

| | |family1 has a financial or other interest? | | |

| |c. |Received any tax, consulting, or advisory services or other personal services from PricewaterhouseCoopers or KPMG (or any of their | | |

| | |affiliates), or from any entity or organization that provides services to, or engages in, transactions with the Company? | | |

| |d. |Control[3] any for-profit entity (excluding New York Life, its subsidiaries and joint ventures)? | | |

| |e. |For the year ended December 31, 2007, retained any accounting firm other than PricewaterhouseCoopers to provide any audit or | | |

| | |audit-related services for the Company. If “yes”, please provide the date and description of the work, whether or not the work is | | |

| | |still on going, and who approved the retention. | | |

| |f. |For the year ended December 31, 2007, retained Deloitte & Touche or KPMG to provide any services whatsoever to the Company. If | | |

| | |“yes”, please provide the date and description of the work, whether or not the work is still on going, and who approved the | | |

| | |retention. | | |

(Please provide complete details of any “yes” answer on Page 8.)

|Compensation, Entertainment and Gifts Involving Others |

| |Yes |No |

|4. |a. |Have you or, to the best of your knowledge, has any member of your family1, received any compensation or other economic benefit that| | |

| | |has not been reported to the Company from any third party in connection with any transaction(s) involving the Company? | | |

| |b. |Have you provided or received any gifts or entertainment that you have failed to report in your department’s gift and entertainment | | |

| | |log if their nature or value required reporting? | | |

| | |(Gifts or entertainment (for example, meals and tickets to events) arising out of or related to your employment involving persons | | |

| | |outside of New York Life are as a matter of course reportable. | | |

| | |(For NYL and NYL International employees - Items valued at less than $10 need not be reported.) Employees of other affiliated | | |

| | |entities should check their separate reporting rules.). See New York Life Online, Policies, Business Conduct, Gifts and | | |

| | |Entertainment.) | | |

(Please provide complete details of any “yes” answer on Page 8.)

|Expenditures on Gifts and Entertainment to Government Employees |

| |Yes |No |

|5. |Have you paid the expenses of, or given any other thing of value (for example, meals, lodging, entertainment, and/or gifts), to an employee | | |

| |or official of any foreign, federal, state, or local government branch or agency (except for those expenses specifically approved by the | | |

| |Office of Governmental Affairs or NYLIM Compliance). | | |

(Please provide complete details of any “yes” answer on Page 8.)

|Contacts with Government Employees |

|6. |In connection with your employment with the Company but excluding any contacts coordinated by the Office of Governmental Affairs, have you had, or do you expect |

| |to have, any contact with any employee or official of any foreign, federal, state, or local government branch or agency with the intent of influencing any |

| |decision involving the Company regarding: |

| | | |Yes |No |

| |a. |Legislation (note: you may exclude voluntary contacts with your legislative representative, or contacts made as part of a | | |

| | |“grassroots” lobbying effort; e.g., taxation of life insurance or insurance benefits or foreign trade matters)? | | |

| |b. |Rulemaking? | | |

| |c. |A financial arrangement (e.g., a purchase or investment)? | | |

| |d. |Any other official decision (e.g., approval of a registration, license, policy application, or advertisement)? | | |

(Please provide complete details of any “yes” answer on Page 8.)

|Foreign Corrupt Practices Act |

|7. |Have you made or offered, or are you aware of any Company employee or agent who has made or offered, any direct or indirect payment or gift to any employee or |

| |official of a foreign government or political party, candidate for foreign political office, or intermediary for the purposes of: |

| | | |Yes |No |

| |a. |Influencing an action? | | |

| |b. |Obtaining favorable treatment or a special concession for the Company, or as payment for favorable treatment or a concession, which | | |

| | |previously has been received on behalf of the Company? | | |

| | | |

(Please provide complete details of any “yes” answer on Page 8)

|Computer Security |

|8. | The Company has an enterprise wide security policy, which recognizes that computer software, hardware, and the information contained therein are proprietary |

| |assets of the Company. It is the responsibility of all employees to ensure that these critical Company assets are established, operated, and maintained in a |

| |secure environment. All employees who have access to the Company's computer and information resources are individually responsible for understanding and |

| |complying with the Company's security policy. |

| | | |Yes |No |

| |a. |Unless previously reported, have you used, or are you aware of any employee who has used, the Company’s computer system and/or | | |

| | |information resources in violation of the information security policy? | | |

| |b. |Are you aware of any employee who has failed to report any violations of this policy? | | |

(Please provide complete details of any “yes” answer on Page 8.)

|International Boycott Reporting Requirements |

| | | |Yes |No |

|9. |a. |To the best of your knowledge, has the Company, its subsidiaries (including any foreign entities in which the Company, or any of its| | |

| | |subsidiaries, owns a 10% or more interest), or its joint ventures, participated in or cooperated with an international boycott | | |

| | |imposed by a foreign country? | | |

| | | | | |

| | |(A person participates in or cooperates with an international boycott if he or she agrees, as a condition of doing business within a| | |

| | |foreign country or with the government, a company, or a national of such country, to refrain from: (i) doing business with another | | |

| | |country or companies or nationals of such country; (ii) doing business with U.S. persons engaged in business with a country or | | |

| | |companies or nationals of such country; (iii) doing business with any company whose ownership or management is of a particular | | |

| | |nationality, race, or religion; or (iv) employing or removing individuals of a particular nationality, race or religion.) | | |

| |b. |To the best of your knowledge, has the Company, its subsidiaries, or its joint ventures been asked to participate in or cooperate | | |

| | |with an international boycott imposed by a foreign country? | | |

| |c. |To the best of your knowledge, has the Company, its subsidiaries, or its joint ventures, had any sales to or operations in, or | | |

| | |related to, any of the following countries, or with the government, a company or nationals of any of the following countries: | | |

| | |Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates, or the Republic of Yemen? | | |

| |d. |To the best of your knowledge, has the Company, its subsidiaries, or its joint ventures, had any sales to or operations in, or | | |

| | |related to, any country, or with the government, a company, or national of any country where it has been required or asked to | | |

| | |participate in an international boycott as a condition of doing business? | | |

| | | | | |

| | |(For purposes of c. and d. above, "operations" would include where business (i) is conducted in whole or in part in a country that | | |

| | |is participating in an international boycott ("boycotting country"); (ii) is conducted outside a boycotting country either for or | | |

| | |with the government, a company or national of a boycotting country; or (iii) is conducted outside a boycotting country for the | | |

| | |government, a company or national of a non-boycotting country, if the person knows or has reason to know that the goods, services or| | |

| | |funds produced by the operations are intended for use in a boycotting country or for the government, a company or national of a | | |

| | |boycotting country.) | | |

(Please provide complete details for any “yes” answer on Page 8.)

|Office of Foreign Assets Control Reporting Requirements |

| | | |Yes |No |

|10. |a. |To the best of your knowledge, has the Company, its subsidiaries, or its joint ventures, or any of their respective departments, | | |

| | |affiliates, subsidiaries, agents, or employees, engaged in any sales, operations, or transactions of any kind whatsoever with, or | | |

| | |related to, the government, nationals, or residents (whether individual, corporate, or otherwise) of any of the following | | |

| | |countries: | | |

| | |Belarus, Burma (Myanmar), Cuba, Democratic Republic of the Congo, Iran, Iraq, Ivory Coast, Liberia, Libya, North Korea, Serbia, | | |

| | |Sudan, Syria, or Zimbabwe? | | |

| |b. |To the best of your knowledge, has the Company, its subsidiaries or its joint ventures, or any of their respective departments, | | |

| | |affiliates, subsidiaries, agents, or employees, engaged in any sales, operations, or transactions of any kind whatsoever with any | | |

| | |person or entity identified on any government list of criminals, narcotics traffickers, or terrorists or terrorist organizations, | | |

| | |including but not limited to the list of Specially-Designated Nationals maintained by the Office of Foreign Assets Control of the | | |

| | |U.S. Treasury? (See: for further details) | | |

(Please provide complete details for any “yes” answer on Page 8.)

|Compliance with Domestic and Foreign Laws, Rules and Regulations |

|11. |a. |Have you, directly or indirectly, been involved[4] in any of the following within the past five years: |

| | | | |Yes |No |

| | |i. |Anti-trust, copyright, or patent litigation? | | |

| | |ii. |Civil or criminal action or administrative proceeding charging a violation of a federal or state securities law or | | |

| | | |regulation? | | |

| | |iii. |Any other criminal action or investigation? | | |

| | |iv. |Representative actions, class actions, or derivative suits (exclude your personal involvement in consumer related class | | |

| | | |actions)? | | |

| | |v. |A formal administrative or regulatory action by any regulatory agency or self-regulatory organization? | | |

| | |vi. |Any bankruptcy, receivership, or insolvency action or proceeding (or been subject to any such action or proceeding)? | | |

| |b. |Have any punitive, exemplary, or extra-contractual compensatory damages been sought, awarded, paid or made part of a settlement | | |

| | |agreement that has been entered into within the past five years in connection with any business activity in which you were | | |

| | |involved4? | | |

| |c. |Have you, or an organization over which you exercised control3 (excluding New York Life, its subsidiaries and joint ventures) at | | |

| | |any time in the past: | | |

| | |i. |Been convicted of or pleaded guilty or nolo contendere (“no contest”) in a domestic, foreign, or military court to: (a) | | |

| | | |any misdemeanor (or its equivalent offense) involving insurance, securities, commodities, banking, real estate, or any | | |

| | | |other investment-related business or activity (collectively referred to as “investment-related activity”); fraud, false | | |

| | | |statements, or omissions; wrongful taking of property; bribery; perjury; forgery; counterfeiting; extortion; or a | | |

| | | |conspiracy to commit any of these offenses or (b) any felony (or its equivalent offense)? | | |

| | |ii. |Been charged with any misdemeanor specified above in question 11.c.i, or any felony? | | |

| | |iii. |Been found by any domestic or foreign court in a civil action or alternative dispute resolution proceeding, or by any | | |

| | | |state or federal governmental authority or agency, self-regulatory organization, or any foreign financial regulatory | | |

| | | |authority5 to have violated, or been involved in a violation of, any law, rule or regulation involving any | | |

| | | |investment-related activity, fraud, false statements or omissions, wrongful taking of property, or unethical behavior? | | |

| | |iv. |Been permanently or temporarily enjoined by any domestic or foreign court, state or federal governmental authority or | | |

| | | |agency, or self-regulatory organization from engaging in any type of business practice or activity (including, but not | | |

| | | |limited to, any investment-related activity)? | | |

| | |v. |Had an action dismissed pursuant to a consent order or decree, or entered into a settlement agreement, in any domestic or | | |

| | | |foreign criminal, civil, administrative, or regulatory proceeding brought against you, or an entity over which you | | |

| | | |exercised control3, (excluding New York Life, its subsidiaries, or its joint ventures) which was associated with any | | |

| | | |investment-related activity? | | |

| |d. |Are you or, based upon the activities that occurred while you exercised control3 over it, is any entity currently the subject of a| | |

| | |pending criminal or regulatory proceeding, which has not been disclosed to the Office of the General Counsel? | | |

| |e. |Has any state or federal governmental authority or agency, or self-regulatory organization (including, but not limited to, the Securities and Exchange |

| | |Commission, the Commodity Futures Trading Commission, or the FINRA), or any foreign financial regulatory authority5 ever: |

| | |i. |Found you to have been involved4 in a violation of its rules or a cause of an investment-related business having its | | |

| | | |authorization to do business denied, suspended, revoked or restricted? | | |

| | |ii. |Imposed a civil money penalty on you, or ordered you to cease and desist from any activity, or have you entered into or | | |

| | | |been subject to a memorandum of understanding or similar written agreement with any such governmental or regulatory | | |

| | | |authority, agency, or organization? | | |

| | |iii. |Disciplined you by expelling or suspending you from membership, barring or suspending you from association with other | | |

| | | |members, or otherwise restricting your activities? | | |

| | |iv. |Denied, suspended, or revoked your registration or license or otherwise prevented you, by order, from associating with an | | |

| | | |investment-related business or restricted your activity? | | |

| | |v. |Imposed a final order on you based on a violation of any laws or regulations that prohibit fraudulent, manipulative, or | | |

| | | |deceptive conduct? | | |

| |f. |In connection with your activities as an employee of the Company, have you ever: |

| | |i. |Engaged in or observed the receipt, in a single transaction, of cash in excess of $10,000 or a combination of cash | | |

| | | |equivalents (e.g., bank drafts, cashier’s checks, money orders or traveler’s checks) each of which was less than $10,000, | | |

| | | |but which together totaled more than $10,000, whether the money came from a legal or illegal source, which was not | | |

| | | |reported to the Company or to appropriate authorities (referred to as the “cash reporting requirement”)? | | |

| | |ii. |Observed a series of transactions that appeared to be structured to avoid the cash reporting requirement by breaking down | | |

| | | |a single sum of cash that exceeded $10,000 into smaller amounts and then engaging in multiple (related or unrelated) | | |

| | | |transactions, each below $10,000, which was not reported to the Company or to appropriate authorities? | | |

| |g. |Have you, in connection with the purchase or sale of securities for your own account, or for an account over which you had the | | |

| | |authority to cause the purchase, sale or other disposition of the securities in such account, traded while in possession of | | |

| | |material, non-public information concerning any issuer of securities or disclosed such information to any other person for other | | |

| | |than a legitimate business purpose? | | |

| |h. |Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any entity controlled3 by you | | |

| | |(excluding New York Life, its subsidiaries and joint ventures) ever been revoked or suspended? | | |

| |i. |Are you now the subject of any investigation or formal administrative or civil action initiated by a governmental agency, | | |

| | |self-regulatory organization, or foreign financial regulatory authority5, or a criminal information or indictment that could | | |

| | |result in a "yes" answer to any part of this Question 11? | | |

| |j. |Are you an appointed officer, director or manager of Eagle Strategies Corp., Eclipse Funds, Eclipse Funds Inc., Institutional | | |

| | |Capital LLC, MacKay Shields LLC, MainStay VP Series Fund Inc., McMorgan & Company LLC, McMorgan Funds Inc., New York Life | | |

| | |Investment Management LLC, New York Life Trust Company FSB, NYLCAP Manager LLC or The MainStay Funds? | | |

| | | | | |

| | |(If you answered “yes” to the question (11j) above, please answer the following question) | | |

| | | | | |

| | |Within the past ten years, based on events that occurred while you exercised control3 over it, has any entity (other than New York| | |

| | |Life, its subsidiaries and joint ventures) been subject to a federal bankruptcy, state insolvency or receivership (including SIPC | | |

| | |receivership) proceeding or made a compromise with creditors? | | |

| | | | | |

(If you answered “yes” to any of the above questions, please provide details on Page 8.)

(If you answered “yes” please provide the requested information on Page 8)

|Interlocks with other Financial Institutions |

| | |Yes |No |

|12. |Are you currently an executive officer, trustee, director, branch manager, or representative serving in any such capacities of a | | |

| |nonaffiliated depository institution or depository holding company, including a savings association, savings bank, bank, commercial bank, | | |

| |co-operative bank, trust company, bank holding company, savings and loan holding company, building and loan association, homestead | | |

| |association, industrial bank, credit union, or an “affiliate” of any such entities (collectively, “Depository Organization”)? | | |

(The term “affiliate” means a person or entity that directly or indirectly through one or more intermediaries’ controls3, or is controlled3 by, or is under common control3 with, the person or entity specified.)

|Registered Representatives, Investment Advisors and Investment Advisory Representatives |

| | Yes | No |

|13. |a. |Are you a Registered Representative of NYLIFE Securities (“NYLSEC”) | | |

| | |or NYLIFE Distributors LLC (“NYLDIST”) | | |

| |b. |Are you an Investment Advisory Representative (“IAR) of NYLIM, MacKay Shields LLC, Eagle Strategies Corp., Institutional Capital | | |

| | |LLC, McMorgan & Company LLC, NYLCAP Manager LLC or | | |

| | |New York Life Trust FSB | | |

| |c. |Are you a Registered Representative or IAR of any other entity or are you personally registered | | |

| | |as an investment advisor with the SEC or any state or jurisdiction? | | |

(If you answered “yes” to any of the questions 13a-c above, please answer the following questions.)

|i. |Specify the name(s) of the broker-dealer(s) or investment advisor(s): |

| | |Yes |No |

|ii. |Have you participated in any way in the distribution or marketing of any securities products other than those distributed through NYLSEC or| | |

| |NYLDIST (e.g., limited partnerships, promissory notes, etc.)? | | |

|iii. |Are you, for a referral fee, recommending customers to unaffiliated firms engaged in the business of providing investment management, | | |

| |brokerage, or similar services? | | |

|iv. |Are you a sponsor or participant in an association of persons formed to invest in securities, (e.g., investment club)? | | |

|v. |Have you or has any person which you have given such information purchased or sold any securities or any other property, real or personal, | | |

| |on the basis such information was known to the Company, its affiliates or any of its employees, but not made available to the general | | |

| |public? | | |

|vi. |Are you the subject of a consumer initiated investment related legal proceeding or written complaint? | | |

|vii. |Have you or any member of your household received, either directly or indirectly, any payments, gifts services, loans, promises of future | | |

| |benefits, or other remuneration from any broker dealer other than NYLSEC or NYLDIST, any issuer of securities, any unaffiliated service | | |

| |provider to NYLSEC or NYLDIST or any customer of NYLSEC or NYLDIST? | | |

|viii. |Have you participated in the purchase of securities in a transaction not involving a public offering without obtaining prior approval from | | |

| |the Compliance Department? | | |

|ix. |If you are a Registered Representative of NYLSEC do you have any brokerage accounts that were not disclosed, via written disclosure, to | | |

| |either New York Life as a covered person under the Company’s Insider Trading Firewall Procedures (via the Corporate Compliance Department) | | |

| |or to NYLSEC (via IPS) as a Registered Representative? | | |

| | | | |

| |If the above answer to question 13 ix is “No,” have there been updates to your prior disclosure, including but not limited to, changes in | | |

| |account status or additional accounts opened that were not provided to the appropriate area of the Company? | | |

| | | | |

(Please provide complete details for any “yes” answer on Page 8.)

Certifications

I understand that in all its operations, it is against Company policy for any employee to cause its books and records to be inaccurate in any way. (Examples would include creating any records that do not accurately reflect the true and complete nature of the transaction; or submitting expense account reports that do not accurately reflect the true nature of the expense.)

I confirm that I have not intentionally withheld, misrepresented, manipulated, or altered any reports or financial filings, or other information to deceive any readers including, but not limited to, Company management, regulatory agencies, any auditors, or others.

I hereby certify that, to the best of my knowledge and belief, the foregoing answers, including the details of any affirmative responses made herein, are true and complete and that I shall update these answers promptly with an amended written response as circumstances change during the year. Please contact John O’Byrne (at 212-576-6556) with respect to any updates.

I further acknowledge that I have an absolute duty to report misconduct. (Employees must report allegations of misconduct, or any ethical concerns, to their supervisor or to the Corporate Office of Business Conduct by calling on 212-576-6556. The Corporate Ombudsperson, 212-576-7236, provides a channel for employees to raise and discuss known or suspected illegal or unethical business conduct without fear of reprisal. Good faith concerns regarding accounting, internal controls or auditing matters also may be reported anonymously to the Audit Committee through the Office of the Secretary by calling 212-576-4489 or 1-800-695-4469.)

I further acknowledge that I am obligated to follow the procedures contained in Integrity, and to cooperate with any investigations or audits of the Company’s operations.

I further acknowledge that if I fail to follow the Company’s policies and procedures, that I may be subject to disciplinary action, up to and including termination of employment. (The Company has the right to terminate an employee for an act of misconduct without a warning.)

I hereby certify that: 1) I have read and understand Integrity - Standards of Business Conduct (“Integrity”) regarding, among other issues, conflicts of interest and compliance with domestic and foreign laws; 2) I have complied with Integrity and the procedures prescribed by the Company, its subsidiaries or joint ventures in furtherance of Integrity; (I understand that, where the subsidiary or joint venture policy may differ in some respects, that the applicable busubsidiary’s or joint venture’s policy requirements will govern my conduct); and 3) I understand that any questions regarding any law or regulation should be directed immediately to the Office of the General Counsel.

Signature: _________________________________ Date: _______________________

Additional Information related to “Yes” responses:

Question 1.

Name of Entity:

Nature of Business:

Position Held:

Period Position Held:

Is the organization for profit? Yes_____ No_____

Is the organization a public company? Yes_____ No______

Question 2.

Question 3.

Question 4.

Name of Person or Payor:

Nature of Transaction:

Amount and Date Paid, Provided or Received:

Question 5.

Jurisdiction:

Name, Title and Agency of Governmental Employee:

Nature, Value & Date of Gift Or Entertainment:

Question 6.

Jurisdiction:

Name, Title and Agency of Governmental Employee:

Nature, Purpose and Date of Contact:

Question 7.

Name of Party:

Amount or Value:

Reason/Date:

Question 8.

Question 9.

Question 10.

Question 11.

Question 12.

Name of Entity:

Location of Entity:

Position Held:

Period Position Held:

Question 13.

K:\Conflicts of Interest\Questionnaires\2007\Conflict of Int Q reformatted.doc

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[1]“Family” means an employee’s spouse, child or other relative, whether related by blood, marriage or otherwise. The term also includes any related or unrelated individual who resides with, or is financially dependent upon, or whose investments are controlled by, or whose financial support is materially contributed to by the employee, such as a “significant other.”

[2] A “Significant Interest” is held by a person in an entity if any of the following apply: (i) an ownership interest of 1% or more is held by such person in a public company, (ii) an ownership interest equal to 10% or more of such person’s net worth is held in any entity, or (iii) an entity is controlled by such person. See footnote 3 for definition of “Control”.

[3] “Control” means the power to direct or cause the direction of the management or policies of a company, whether through ownership of securities, by contract, or otherwise. A person is presumed to control a company if such person serves as a director of that company, or serves as a partner or officer of that company exercising executive responsibility (or having similar status or functions), or if such person has the right to vote 25% or more of its voting securities or is entitled to 25% or more of its profits.

[4] “Involved” for purposes of Question 11 does not include acting solely as an attorney, representative, or witness in a proceeding on behalf of New York Life Insurance Company, its subsidiaries and joint ventures.

5 “Foreign Financial Regulatory Authority” includes a foreign securities authority; any other governmental body or foreign equivalent of a self-regulatory organization empowered by a foreign government to administer or enforce its laws related to the regulation of ‘investment-related activity’ (as defined in Question 11c(i)); or a membership organization, a function of which is to regulate the participation of its members in ‘investment-related activity’ (as defined).

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