MetLife Investment Funds, Inc. – ‘N-CSR’ for 12/31/04 – EX-99.CODE ETH

On:  Monday, 3/14/05, at 9:54am ET   ·   Effective:  3/14/05   ·   For:  12/31/04   ·   Accession #:  950123-5-3054   ·   File #:  811-07450

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Certified Annual Shareholder Report of a Management Investment Company   —   Form N-CSR
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: N-CSR       Certified Annual Shareholder Report of a             250±   838K 
                          Management Investment Company                          
 4: EX-99.906CERT  Certifications                                      1      7K 
 3: EX-99.CERT  Certifications                                         6     20K 
 2: EX-99.CODE ETH  Code of Ethics                                     7     21K 

EX-99.CODE ETH   —   Code of Ethics

EX-99.CODE ETH
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                                                               November 14, 2003

CITISTREET FUNDS, INC.
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
 SENIOR FINANCIAL OFFICERS

I.    COVERED OFFICERS/PURPOSE OF THE CODE                                      

This code of ethics (the "Code") for CitiStreet Funds, Inc. (the    
"Company") applies to the Company's Principal Executive Officers, Principal     
Financial Officer and Principal Accounting Officer (the "Covered Officers," each
of whom is set forth in Exhibit A) for the purpose of promoting:                

      -     honest and ethical conduct, including the ethical handling of actual
           or apparent conflicts of interest between personal and professional
relationships;                                          

-     full, fair, accurate, timely and understandable disclosure in 
          reports and documents that a registrant files with, or submits to,
          the Securities and Exchange Commission ("SEC") and in other public
communications made by the Company;                     

-     compliance with applicable laws and governmental rules and    
regulations;                                            

-     the prompt internal reporting of violations of the Code to an 
 appropriate person or persons identified in the Code; and

-     accountability for adherence to the Code.                     

    Each Covered Officer should adhere to a high standard of business ethics
and should be sensitive to situations that may give rise to actual as well as   
apparent conflicts of interest.                                                 

II.   COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF 
INTEREST                                                            

      OVERVIEW. A "conflict of interest" occurs when a Covered Officer's private
interest interferes with the interests of, or his or her service to, the        
Company. For example, a conflict of interest would arise if a Covered Officer,  
or a member of his family, receives improper personal benefits as a result of   
his or her position with the Company.                                           

Certain conflicts of interest arise out of the relationships between
Covered Officers and the Company and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 (the "Investment Company Act") 
and the Investment Advisers Act of 1940 (the "Investment Advisers Act"). For    
example, Covered Officers may not individually engage in certain transactions   
(such as the purchase or sale of securities or other property) with the Company 
because of their status as "affiliated persons" of the Company. The Company's   

EX-99.CODE ETH
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compliance programs and procedures are designed to prevent, or identify and     
correct, violations of these provisions. This Code does not, and is not intended
to, repeat or replace these programs and procedures, and such conflicts fall    
outside the parameters of this Code.                                            

  Although typically not presenting an opportunity for improper personal
benefit, conflicts arise from, or as a result of, the contractual relationship  
between the Company and CitiStreet Funds Management LLC (the "Manager") and its 
affiliates, of which the Covered Officers are also officers or employees. As a  
result, this Code recognizes that the Covered Officers will, in the normal      
course of their duties (whether formally for the Company or for the Manager, or 
for both), be involved in establishing policies and implementing decisions that 
will have different effects on the Manager and the Company. The participation of
the Covered Officers in such activities is inherent in the contractual          
relationship between the Company and the Manager and is consistent with the     
performance by the Covered Officers of their duties as officers of the Company. 
Thus, if performed in conformity with the provisions of the Investment Company  
Act and the Investment Advisers Act, such activities will be deemed to have been
handled ethically.                                                              

Other conflicts of interest are covered by the Code, even if such   
conflicts of interest are not subject to provisions in the Investment Company   
Act and the Investment Advisers Act. The following list provides examples of    
conflicts of interest under the Code, but Covered Officers should keep in mind  
that these examples are not exhaustive. The overarching principle is that the   
personal interest of a Covered Officer should not be placed improperly before   
the Company.                                                                    

Each Covered Officer must:                                          

     -     not use his personal influence or personal relationships improperly
       to influence investment decisions or financial reporting by the
           Company whereby the Covered Officer would benefit personally to the
detriment of the Company;                               

   -     not cause the Company to take action, or fail to take action, for
          the individual personal benefit of the Covered Officer rather than
the benefit of the Company; and                         

   -     not retaliate against any other Covered Officer or any officer or
          employee of the Company or its advisers or other service providers
          for reports of potential violations of this Code or applicable law
that are made in good faith.                            

     The following conflict of interest situations involving a Covered Officer
or a member of his or her immediate family should be approved by the Chairperson
of the Company's Governance Committee:                                          

-     service as a director on the board of any public company;     

  -     the receipt of any gifts in excess of $100 from any company with
       which the Company has current or prospective business dealings;

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  -     the receipt of any entertainment from any company with which the
        Company has current or prospective business dealings unless such
           entertainment if reasonable in cost and not so frequent as to raise
any question of impropriety;                            

-     any ownership interest in, or any consulting or employment    
        relationship with, any of the Company's service providers, other
            than CitiStreet LLC, Citigroup Inc., State Street Corporation or any
of their affiliates; and                                

-     any direct or indirect financial interest in commissions,     
        transaction charges or spreads paid by the Company for effecting
         portfolio transactions or for selling or redeeming Company shares
 other than an interest arising from the Covered Officer's
        employment, such as employment compensation or equity ownership.

      The Chairperson of the Governance Committee shall report any such approval
or disapproval to the Governance Committee at its next meeting.                 

III.  DISCLOSURE AND COMPLIANCE                                                 

     -     Each Covered Officer should familiarize himself or herself with the
    disclosure requirements generally applicable to the Company.

  -     Each Covered Officer should not knowingly misrepresent, or cause
          others to misrepresent, facts about the Company to others, whether
           within or outside the Company, including to the Company's directors
      and independent accountant, and to governmental regulators and
self-regulatory organizations.                          

IV.   REPORTING AND ACCOUNTABILITY                                              

Each Covered Officer must:                                          

-     upon adoption of the Code (or thereafter as applicable, upon  
      becoming a Covered Officer), affirm in writing to the Board of
         Directors of the Company (the "Board") that he has received, read
      and understands the Code (in the form set forth as Exhibit B);

      -     annually thereafter certifies to the Board that he has complied with
          the requirements of the Code (in the form set forth as Exhibit B);
and                                                     

   -     notify the Chairperson of the Governance Committee promptly if he
         knows of any violation of this Code. Failure to do so is itself a
violation of this Code.                                 

     The Governance Committee (or its Chairperson) is responsible for applying
this Code to specific situations in which questions are presented under it and  
has the authority to interpret this                                             

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Code in any particular situation. However, any approvals of waivers(1/) sought  
by a Covered Officer will be considered by the Governance Committee (or its     
Chairperson).                                                                   

   The Company will follow these procedures in investigating and enforcing
this Code:                                                                      

-     the Governance Committee Chairperson will take all appropriate
           action to investigate (or direct an investigation of) any potential
violations reported to him;                             

     -     the Governance Committee Chairperson will report the results of the
investigation to the Governance Committee;              

-     if the Governance Committee determines that a violation has   
        occurred, it will inform and make a recommendation to the Board,
            which will consider appropriate action, which may include review of,
 and appropriate modifications to, applicable policies and
            procedures; notification to appropriate personnel of the Manager; or
    a recommendation to sanction or dismiss the Covered Officer;

-     the Committee will be responsible for granting waivers, as    
appropriate; and                                        

      -     any changes to or waivers of this Code will, to the extent required,
be disclosed as provided by SEC rules.                  

V.    OTHER POLICIES AND PROCEDURES                                             

 This Code shall be the sole code of ethics adopted by the Company for
purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms       
applicable to registered investment companies thereunder. Insofar as other      
policies or procedures of the Company, the Manager, the Company's subadvisers,  
the Company's principal underwriter or other service providers govern or purport
to govern the behavior or activities of the Covered Officers who are subject to 
this Code, they are superseded by this Code to the extent that they overlap or  
conflict with the provisions of this Code. The Company's and the Manager's codes
of ethics under Rule 17j-1 under the Investment Company Act and the Manager's   
more detailed policies and procedures are separate requirements applying to the 
Covered Officers and others, and are not part of this Code.                     

VI.   AMENDMENTS                                                                

    Any amendments to this Code, other than amendments to Exhibit A, must be
approved or ratified by a majority vote of the Board, including a majority of   
independent directors.                                                          

----------                                                                      

(1/)Item 2 of Form N-CSR defines "waiver" as "the approval by the   
registrant of a material departure from a provision of the code of ethics" and  
"implicit waiver," which must also be disclosed, as "the registrant's failure to
take action within a reasonable period of time regarding a material departure   
from a provision of the code of ethics that has been made known to an executive 
officer" of the registrant.                                                     

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VII.  CONFIDENTIALITY                                                           

     All reports and records prepared or maintained pursuant to this Code will
be considered confidential and shall be maintained and protected accordingly.   
Except as otherwise required by law or this Code, such matters shall not be     
disclosed to anyone other than the Board and its counsel.                       

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 EXHIBIT A

 Persons covered by this Code of Ethics:

Robert Dughi (Principal Executive Officer)
 Paul Feinberg (Principal Executive Officer)
Matthew Riordan (Principal Financial and Accounting Officer)

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 EXHIBIT B

CitiStreet Funds, Inc.

Code of Ethics for Principal Executive and
 Senior Financial Officers

 Certification

[All certifications] The undersigned hereby certifies that he/she has received  
and read, and understands, the Code of Ethics for Principal Executive and Senior
Financial Officers of CitiStreet Funds, Inc., dated November 14, 2003 (the      
"Code").                                                                        

[Annual certifications] The undersigned hereby certifies that he/she has        
complied with the Code during the period _________________.                     

                             _____________________________________
Name    
Title   
              CitiStreet Funds, Inc.

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Dates Referenced Herein   and   Documents Incorporated by Reference

				Referenced-On Page
This ‘N-CSR’ Filing		Date		First		Last			Other Filings
Filed on / Effective on:		3/14/05
For Period End:		12/31/04							24F-2NT,  NSAR-B
		11/14/03		1		7
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