Rule 35d-1 under the Investment Company Act of 1940 (the Names Rule) was originally adopted in 2001, and amendments to the Names Rule were finalized in September 2023 with an effective date of December 11, 2023, and the compliance date of December 11, 2025, for larger entities and June 11, 2026, for smaller entities. On March 14, 2025, the SEC announced a six-month extension of these compliance dates to allow funds additional time to implement the amendments properly, develop and finalize their compliance systems, and test their compliance plans. The new compliance dates are June 11, 2026, for larger funds and December 11, 2026, for smaller funds. On January 8, 2025, the Division of Investment Management published a Frequently Asked Questions (FAQ) regarding the Names Rule.

While the Names Rule is not applicable to private funds, it does establish principles regarding fund naming conventions and representations to fund investors regarding fund investment strategies and focus areas. These principles can be instructive to private fund managers, who are prohibited under Rule 206(4)-8 of the Investment Advisers Act from making any misleading statements to investors or prospective investors in pooled investment vehicles.