Aug. 15, 2022
Gary Gensler, Chair SEC Headquarters 100 F Street, NE Washington, DC 20549 (202) 551-2100 chairmanoffice@sec.gov Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 rule-comments@sec.gov, help@sec.gov Re: Investment Company Names (File No. S7-16-22);,Enhanced Disclosures by Certain Investment Advisers and Investment Companies about,Environmental, Social, and Governance Investment Practices (File No: S7-17-22) Dear Chairman and Secretary: Americans for Financial Reform Education Fund (AFREF) submitted comments, https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-e96ff56d825552b7&q=1&e=33a007d2-1fb3-4500-9835-3479bbb7bfbc&u=https%3A%2F%2Fourfinancialsecurity.org%2Fwp-content%2Fuploads%2F2022%2F08%2FESG-rules-AFREF-technical-comment.pdf, on the proposed rules regarding fund names and required Environmental, Social, and Governance (ESG) disclosures for investment funds and advisers. These proposed rules would require that investment funds with sustainability-themed names like “ESG”, “Green” or “Socially Responsible” would have to disclose their investment strategy, shareholder engagement, and progress towards achieving their stated ESG-related goals and impacts. Environmentally focused fund would additionally need to disclose their financed greenhouse gas (GHG) emissions. AFREF offered recommendations to strengthen the proposals. Take the time to review these recommendations and give them the weight they deserve. Yours sincerely, Robert E. Rutkowski cc: Legislative Correspondence Team 1705 Longworth House Office Building Washington DC 20515