CFA submitted comments in support of a proposal by the Securities and Exchange Commission (SEC) that would, among other things: expand the scope of the current Names Rule to cover a broader set of fund naming conventions that have the potential to be misleading or deceptive; apply the rule to instances when funds’ portfolios change, either through active management decisions or passive market developments, and may no longer be accurately reflected by their funds’ names; modernize the rule to better reflect funds’ increased use of derivatives; and address the growing use of Environmental, Social, and Governance (ESG) or similar terminology in fund names. These proposed rule changes are urgently needed to protect the many investors that reasonably rely on the accuracy and reliability of fund names when making investment decisions and throughout the duration of their investments.