The Investment Company Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a proposal relating to investment company names, Release No. IC-22530, File No. S7-11-97.  The proposal contains certain rule proposals relating to the use of descriptive fund names to identify the principal focus of certain funds.  SIA holds grave reservations concerning the functionality of certain aspects of the proposals relating to the use of descriptive fund names, and details their concerns.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.