Response to SEC Request for Comment on Fund Names

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The Bottom Line:  Response to SEC’s RFC on Fund Names to such terms and “ESG” or “Sustainable” proposes for consideration a potential fund classification framework.

This comment note was submitted on May 5, 2020 in response to the SEC’s Request for Comment (Release Nos. IC-33809; File No. S7-04-20) on Fund Names, in particular as it relates to the application of the Names Rule to such terms and “ESG” or “Sustainable.”  The response supports extending the Names Rule to encompass fund strategies, including sustainable investing strategies covering 100% of portfolio assets and goes on to advocate for the adoption of a classification framework requiring funds to categorize themselves and their strategies for the benefit of investors and other interested parties as a prerequisite to amending the Fund Names rule.  To this end, a potential  classification framework is proposed.  The complete response can be downloaded here.  

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