May 5, 2020

Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: Request for Comments on Fund Names File No. S7-04-20

Dear Ms. Countryman:

The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to provide comments to the United States Securities and Exchange Commission (the “Commission” or “SEC”) on the Commission’s request for public comment on the framework for addressing names of registered investment companies and business development companies, governed by section 35(d) of the Investment Company Act of 1940, as amended (the “Investment Company Act” or the “1940 Act”), rule 35d-1 thereunder (the “Names Rule”), and the antifraud provisions of the Federal securities laws.2 AMG is very supportive of this solicitation of public comments on the Names Rule and the associated challenges the industry has faced over the nearly twenty years since its adoption. Feedback from market participants will provide the Commission with important perspective to help shape a more efficient and robust regulatory evaluation of fund names. SIFMA AMG gathered input from many member firms and we are pleased to provide feedback on a number of the topics and questions included in the Request in furtherance of the Commission’s efforts.

I. INTRODUCTION

Section 35(d) of the 1940 Act provides protections to investors of all funds, regardless of whether a fund is subject further to rule 35d-1. This section makes it unlawful for a fund to use in its name “any word or words that the Commission finds are materially deceptive or misleading.” This general guideline applies to any fund and any words used in a fund name. Section 35(d) also authorizes the Commission to designate specific fund names by rule that would be materially deceptive or misleading. The Commission did so in adopting the Names Rule in 2001.