Subject: File No. S7-04-20
From: Janet Beirbaum

March 31, 2020

I think the Names Rule is very important. Questioning its purpose is like asking whether the SEC should prevent fraud. Yes. It should.

ESG should be subject to the Names Rule as should any fund name that can possible subject to an 80% test.

I think the 80% policy should only be changed under the most drastic circumstances and subject to strict oversight.