Jun. 08, 2022
June 8, 2022 I thought the names rule worked pretty well as it was. All derivatives to count for the 80% test and make sure ESG is covered by the rule. Otherwise, leave it alone. I also believe their should be a marketing component a to the rule. If a fund is going to changes its name, 80 percent policy or strategy, once the 60 day notice goes out, all marketing materials should include a legend to out perspective investors on notice. Finally, it is one thing to allow thebuse of well established trade names in a fund's name without I think trigger the rule. However, this need to be locked down. An adviser cannot just call itself Crypto Advisers and roll out a crypto fund without an 80% test.