On May 25, 2022, the Securities and Exchange Commission (the “SEC”) voted 3 to 1 (Commissioner Peirce dissenting) to propose certain amendments to Rule 35d-1 (the “Names Rule”) under the Investment Company Act of 1940 (the “Investment Company Act”). The Names Rule is intended to ensure that the name of a registered investment company or business development company (“BDC” and, together, a “fund”) does not misrepresent the fund’s investments and risks. The proposed amendments follow a number of public statements by SEC Chair Gensler and other commissioners, as well as actions by the SEC staff, suggesting a growing focus on “truth in advertising” when it comes to fund naming and marketing to investors, particularly with respect to funds that market themselves as “green” or “sustainable” or otherwise focused on environmental, social or governance (“ESG”) criteria.