May 2022
The SEC’s proposed changes to the Investment Company Act’s Names Rule, and enhanced disclosures related to ESG, are intended to bring investors enhanced transparency with regard to ESG strategies. The SEC is seeking to mitigate potential “greenwashing” by placing increased accountability on investment advisors to disclose, in sufficient detail, the investment process consistent with the name of a fund and investors’ expectations. The proposals are in line prior SEC’s Risk Alert, public statements and supervisory/enforcement focus relative to the importance of ESG fund transparency.