Subject: File No. S7-04-20
From: Jason K

March 7, 2020

I agree that the Names of funds are an important and should be lan honest reflection of what the fund does. Investors should not have to cross check a name against long regulatory disclosures to confirm that a fund does what a name suggests.

Funds should be given to flexibility to invest in various types of investments so long as they have the same economic effect as the type of investments suggested by their name.

I am also concerned by funds using hot names to gather assets. Puffery may be ok, but many funds stretch names too far.

Also, it is nice that the SEC regulated fund names. However, I think there needs to be more enforcement cases in this area. I do not think there have been any in 20 years and there are plenty of offenders to go after, such as the LJM Capital Preservation Fund or the Navigator Sentry Managed Risk Fund. Both unexpectedly lost 80% of their value under strong market conditions.

Good luck and be reasonable.



PS It was not easy to find this comment form.