Subject: File No. S7-04-20
From: sean Xing

March 15, 2020

Fund names are quite important. They are often the basis for an investoe to dig deeper into a possible investment. Funds must be honest.

ESG is all the rage these days. I think ESG must be subject to an 80% test.

Finally, as a data scientist, I question the use of text analytics to comply with the names rule. I find that funds often overemphasize certain activities in their filings when they are a small percentage of threat business.

For instance a $20 billion company may rout their recycling program and carbon recapture, which is good and all. However, it may be described thoroughly in their 10-k but may not be a driver of performance and account for a negligible amount of a businesses activities and expenditures. This may put companies in an ESG category which really they should not be in. Another example is cyber security. Just because a company uses the term a lot does not mean it is a cyber security company. Perhaps they had a breach or perhaps they are trying to give their investors some solace as to precautions they have in place. Some funds devote a significant portion of their disclosures to describe these things. So, I think the SEC should be cautious before allowing text analytics to determine compliance with the names rule.