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Comments to SEC on Investment Company Names

The SEC has proposed a rule that would better align the names of investment companies with investor expectations, including for Environmental, Social, and Governance (ESG) investment funds, by requiring portfolio distribution requirements for funds whose name connotes a particular investment strategy. We submitted comments on the SEC's economic analysis of the Proposed Rule. We commend the Commission for complying with relevant case law and internal guidance on cost-benefit analysis and recommend steps that the SEC could take in the final rule to provide additional clarity and context regarding its findings.