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![handle is hein.amenin/aeiaeme0001 and id is 1 raw text is: AMERICAN
ENTERPRISE
INS]T TUT
Comment to the Securities and Exchange Commission
On the Investment Company Names Proposed Rule
Benjamin Zycher*
Senior Fellow, American Enterprise Institute
November 1, 2022
Securities and Exchange Commission
File No. S7-16-22, RIN 3235-AM72
Federal Register Vol. 87, No. 117, June 17, 2022, pages 36594-36651
Submitted through the SEC internet comment portal:
https://wwwsec~gov/ci-bin/riiing-comments
This comment is submitted to the Securities and Exchange Commission on the proposed
rule on Investment Company Names. The central conclusion is straightforward: Because the
proposed rule ignores basic fundamentals of market competition, it would yield few if any
economic benefits for investors while imposing substantial costs. Accordingly, it should not be
finalized in its current form. This comment is organized as follows:
Summary.
The Misleading Nature of the Terms Deceptive or Misleading.
Can Every Investor Be Fooled? The Discipline Imposed by Marginal Investors and the
Economic Returns to Reputational Capital.
Environmental, Social, and Governance Funds and the Problem of Non-Definition.
Conclusions: This Proposed Rule Is Fundamentally Deceptive and Incoherent.
* Ph.D., Economics, University of California, Los Angeles. The views expressed in this comment are solely those of
the author, and do not purport to represent those of the American Enterprise Institute of any of its officers or
sponsors.
1 The proposed rule has been published as File No. S7-16-22, RIN 3235-AM72 in the Federal Register at
https://www. o-info.Asov/cotet/Ipk/FR 2( 2'22-6. -17/pdf/2022-1 1742.pdf.
The American Enterprise Institute (AEI) is a nonpartisan, nonprofit, 501(c)(3) educational organization and
does not take institutional positions on any issues. The views expressed in this testimony are those of the
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