On September 20, 2023, the SEC finalized updates to the Names Rule to prevent greenwashing and address ESG factors (88 Fed. Reg. 70436, Oct. 11, 2023), which were first proposed in June of 2022 (87 Fed. Reg. 36594, June 16, 2022). The amendments clarify and expand requirements for certain funds to invest at least 80% of their assets in accordance with the investment focus suggested by the fund’s name. Specifically, the amendments apply the 80% investment requirement to any fund with a name that includes terms suggesting that the fund focuses on investment with particular characteristics. This includes, in addition to fund names that imply investments in a specific industry, country, or geographic region, fund names with terms such as “growth” or “value,” and terms indicating that the fund’s investment decisions incorporate one or more ESG factors. “ESG” terms include “socially responsible,” “sustainable,” and “green,” if they describe a focus that investors may consider relevant when investing. Fund groups with net assets exceeding $1 billion have 2 years to comply with the amendments and those with assets under $1 billion have 30 months.