
MONTH-IN-BRIEF (Jan 2025)
SEC Staff Issues 2025 Names Rule FAQs
By Karen Liu, Reid & Wise LLC
On January 8, 2025, the staff of the Division of Investment Management (the “Staff”) under the U.S. Securities and Exchange Commission (the “SEC”) released the 2025 Names Rule FAQs, which is an update of the Staff’s 2001 Names Rule FAQs, by withdrawing some questions and answers (“Q&As”) and amending other Q&As.
On September 20, 2023, the SEC adopted amendments (the “2023 Names Rule”) to Rule 35d-1 under the Investment Company Act of 1940 (the “Company Act”). The 2023 Names Rule took effect on December 10, 2023. Its compliance date is December 10, 2025, for larger entities, and June 10, 2026, for smaller entities.