Subject: S7-16-22: WebForm Comments from Matt Grinnell
From: Matt Grinnell
Affiliation: Linedata

Aug. 17, 2022

The Fund's Name test is regarding as the benchmark indicator of 'truth in labeling'.  If an Investment Company chooses to use terminology in the name then, by default, it must be significant to the Fund.  And if those terms are not indisputably defined in common reference texts then I believe it is the responsibility of the Investment Company and Adviser to provide a detailed explanation of the meaning of these terms and how they influences the operations of the Funds.  Otherwise they should just use a numeric identifier as the Name to eliminate any ambiguity.