The Securities and Exchange Commission recently adopted significant changes to Rule 35d-1 under the Investment Company Act of 1940 (Names Rule), as well as certain forms and disclosure requirements on September 20, 2023 (Amendments). Among other changes, the Amendments:

Significantly expand the 80% investment policy requirement to include fund names with terms suggesting an investment focus in investments that have, or whose issuers have, “particular characteristics,” including “growth,” “value” and terms indicating that the fund’s “investment decisions incorporate one or more [ESG] factors.”