Amendments To The Names Rule

On September 20, 2023, the SEC adopted amendments to the Names Rule (35d-1) that will significantly expand the Names Rule's applicability and will require all funds to consider whether changes are required to their names, 80% policies, disclosures, compliance tests and reporting requirements.

In summary, under the final rule, fund names with terms that suggest such funds focus in investments that have, or investments whose issuers have, particular characteristics will be required to have an 80% policy. The SEC declined to define "particular characteristics" but stated that covered terms include "growth" and "value," terms with ESG- or sustainability-related characteristics, and terms that reference a thematic focus. Terms used in the fund's name that suggest an investment focus or that the fund's distributions are tax-exempt must be defined consistently with such terms' plain English meaning or established industry use in the fund's prospectus, which must also