Subject: S7-16-22: WebForm Comments from Nate Regan
From: Nate Regan
Affiliation:

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.