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Client Alerts

Investment Funds & Private Capital Market Insights: SEC’s Final Amendments to Fund “Names Rule” and Procedures

October 10, 2023

By Michael R. Rosella,David A. Hearth,& Thomas D. Peeney

On September 20, 2023, the Securities and Exchange Commission (the “SEC”) adopted amendments to Rule 35d-1 (the “Names Rule”) under the Investment Company Act of 1940, as amended, which is intended to prohibit the use of fund names that the SEC thinks have the potential to mislead investors about a fund's investments and risks. The SEC claims that the changes modernize and strengthen the Names Rule to enhance investor protection and address developments in the fund industry over the past 20 years since it was originally adopted.

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