March 3, 2020
A funds name is a compelling piece of information. It drives investment decisions. If I like an advisor and an asset class, I might Google the name of the advisor and asset type and will come to a fund with those terms in the fund name. I would say I look at a fund's name, performance (compared to the SP), and fees, in that order, when picking my investments.
Funds should do what a name suggests it does. An 80% requirement seems reasonable. It should apply to types of investments, strategies, and the like. The standard should be 80% of a funds economic exposure. That could be assets or for some types of funds it may count derivatives exposure (if it looks and feels like a direct investment, and doesnt impose additional material risks).
Funds that have a term like ESG in the name should also be subject to an 80% test that s spelled out clearly in the funds disclosure documents. Issuers and regulators should not be required to spell out what ESG is. Intelligent minds can differ. Some thing nuclear energy is clean, others think it is not environmentally friendly. So think the right to an abortion is socially responsible, others believe strongly it is not. It is not the place of the government to inject itself in any determinations. Rather, it should simply mandate that is be explained to investors.
I have little sympathy for nacent industries. For example, if the fortunes of a company cant be said to be tied to blockchain, then it is not in the blockchain industry. Even if it was, it still might not be in the industry. Blockchain is a technology. It is no different than a hair drier manufacturer saying it is in the electric energy industry or a food manufacturer saying it is in the computer business just because they use computers to do their jobs.
Thanks for thinking about how to best protect investors.