Subject: File No. S7-04-20
From: Sam Janain

March 23, 2020

The Names Rule largely has worked well and should stay in place. Reasonable accommodations for odd types of investments.

ESG is a type of investment and should be subject to the rule.

One think not asked about is leveraged funds. I think funds with high amounts of leverage (actual or economic) should be made clear from the fundso name.

The Names Rule takes issue with funds that do not have enough exposure to what is suggested by its name. What about funds with too much exposure. For instance a leverage bond fund can make it far more risk than a typical bond fund. This added risk needs to be flagged early. The earliest and most ubiquitous way to flag is to add a notation to the funds name.

Also, bring more enforcement in this area. Lets keep funds honest.

Also, limit the amount of time for temporary defensive positions, I think some funds have gone off the reservation with this. At some point, temporary becomes normal.