Names Rule compliance that proves every word of a fund's name with its holdings, every night
Every word in a fund's name proven by its holdings, in every language, every night.
See one case, screen by screen ↓Names Rule compliance is proving that every word in a fund's name that suggests a focus — including ESG terms like “sustainable” — is backed by an 80% investment policy, defined in the prospectus, reviewed at least quarterly and restored, generally within 90 days, after a departure, as SEC Rule 35d-1 requires. Fund Names Rule Compliance tests each name term against its policy and holdings every night under SEC and ESMA rules, with eight agents that map, test, check, read issuers, plan the cure and check every language, while analysts approve and the Fund CCO signs.
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Names Rule compliance means every word in a fund's name that suggests a focus — an investment type like “Bond”, a region like “Emerging Markets”, a characteristic like “Sustainable” — is backed by an 80% investment policy, defined in plain English in the prospectus, reviewed at least quarterly and restored, generally within 90 days, after a departure. Under the SEC's amended Rule 35d-1, larger fund groups had to comply by June 11, 2026 and smaller ones by December 11, 2026. In Europe, the ESMA fund naming guidelines add Paris-aligned or Climate Transition exclusions for every name a fund is sold under, in every language.
Today the inventory of names lives in a spreadsheet, and an analyst hand-codes each basket from the prospectus into the compliance engine. A vendor downgrade silently tips a fund out, and nobody checks it against the issuer's own report — which is often in Spanish, Turkish or Indonesian. The 90-day clock lives in someone's calendar, the cure is a chain of emails with the portfolio manager, a separate team in Luxembourg runs the ESMA test, and no one checks that the French, German or Italian name says what the English says. When an examiner asks why a fund met its name, the answer takes weeks and five systems.
Estimated split for one quarter's review of a fund range like the one in the working solution, by hand and with the solution.
Eight agents map, test, check, read the issuers, plan the cure and check every language; people approve, decide and sign.
Quillfield Sustainable Emerging Markets Bond Fund — Class I QSEIX, $1,486.2M in net assets, 214 positions in 96 issuers across 31 countries, on the amended rule since its 485(b) of July 29, 2026. At quarter end “Sustainable” stood at 81.9%. Three vendor changes later it is 77.4%. It is Monday, October 19, 2026, and the Q3 review is due Friday, October 30. Here is how the compliance analyst, the portfolio manager and the Fund CCO work it with the agents, screen by screen.
Rachel's day opens on four plain numbers: 326 name terms tested at 6:00 a.m., 3 below 80% with a cure clock each, 11 needing a person's decision and 5 sign-offs waiting for the CCO. Under “Needs you”, six items, one step each: decide a red flag where the sources disagree, the cure plan with the portfolio manager, two computations that differ on the Global Water Fund, 7 holdings without ESG data, 18 tests to approve and a delayed vendor feed the tests are working around. Beside it runs the crew's overnight thread, each agent saying what it did and what it needs.
Holdings Tester, 6:02 a.m.: “Tested 326 name terms across 318 funds and share classes on 68,214 holdings. 3 are below 80%, 9 are on watch between 80% and 82%.”
The name is split into its terms: Quillfield, Sustainable, Emerging Markets, Bond. Under each sits its type, its prospectus definition with the cited page and a meter against the 80% line and the firm's 82% buffer. “Sustainable” — green, social or sustainability bonds aligned with the ICMA principles, or issuers rated Leader or Advanced with no red-flag controversy — reads 77.4%: 168 of 214 positions, $1,150.3M of $1,486.2M. Emerging Markets is at 91.3% and Bond at 96.8%. The Check agent recomputed all three on a separate snapshot with a different method, and agrees.
“Quillfield” is marked Brand — no 80% policy needed.
Rachel asks the crew in plain words. The Holdings Tester answers with the three vendor changes, each cited: Andina Power Transmission from Advanced to Average on Oct 8 (−2.1), a red flag on Bosphorus Cement on Oct 14 (−1.0), and a red flag on Nusantara Pulp & Paper on Oct 16 (−1.4). She asks which trades fix it, and the Cure Planner answers from the plan it has already drafted.
Cure Planner: “Six trades restore 82.1%; T1–T4 alone restore 80.6% and keep the cash for the Oct 23 redemption. Ana decides each trade; compliance releases the orders.”
For each downgrade the agent read the issuer's own report and set the original beside the English with the page: Andina's Spanish Memoria Anual, p. 87, and Bosphorus's Turkish disclosure both support the vendor. Nusantara does not settle. Vendor A flags deforestation after an NGO report of Sep 30; vendor B has no flag; the Indonesian sustainability report, p. 33, says the company's own concessions were certified at the end of 2025; a third-party report maps 3,100 hectares cleared inside a supplier's concession in 2026. The agent is 62% sure — below its 85% line — so it asks.
“The sources disagree. … I cannot settle this from the documents.” Verdict: I need you to decide.
Rachel takes the conservative choice. She treats Nusantara as out until resolved, picks the reason code DATA-CONSERVATIVE and writes the note that goes on the record. The decision overrides one vendor, so it joins the Fund CCO's sign-off queue as a data override with the issuer's page and the NGO report attached.
“This overrides one source. The CCO signs it.”
The departure was recorded on Oct 8, and at 7:12 a.m. the Cure Planner drafted six trades from Ana's approved buy list v14, each with its source, its effect on “Sustainable” and a pre-trade check — one point of the meter is $14.86M. Ana accepts four: Andina into a Hidroandina Verde green bond (+1.26), Nusantara into a Java Solar green sukuk (+0.90), a Lagos Water sustainability bond from cash (+0.50) and Bosphorus into an Anatolia Wind green bond (+0.54). She declines Mekong Rail for liquidity and the Pacífico social bond to keep cash. The meter moves from 77.4% to 80.6%, with every other limit inside its band.
Ana's reason on T6 (CASH): “A $41.0M redemption is expected Oct 23 from a model portfolio. I keep the cash.”
Ana sends her decisions to compliance; she cannot release them herself. Rachel opens Check and release: her decisions are matched to the plan — 4 accepted, 2 declined with reasons LIQ and CASH — each accepted trade passes the pre-trade names test with every term and limit within, seven orders are staged in the order management system, and the departure record and cure plan go to the CCO.
“Traders execute; nothing sent without this release.”
The UCITS sibling, Quillfield Funds SICAV – Sustainable Emerging Markets Bond Fund (€612.4M, 6 share classes), passes the 80% test for environmental or social characteristics at 83.0% and holds 46.2% sustainable investments against an annex minimum of 40%. But “Sustainable” is a sustainability term, so Paris-aligned exclusions apply, and Andina Power Transmission — 54% thermal revenue, by its own report — fails the exclusion for electricity generation above 100 g CO2e/kWh. Claire records a passive breach; policy says correct within 30 business days. The French Durables and German Nachhaltige names make the same claim as the English.
EU Names agent, 6:20 a.m.: “ESMA test on 40 EU sub-funds: 1 Paris-aligned exclusion hit (Andina, Sustainable EM Bond sibling).”
Thomas's queue holds every exception with its due date: the departure record and cure plan, a cure-plan update, a definition change for the Clean Energy Fund, a new Holdings Tester version, the Q3 certification and Rachel's data override. The departure record shows who prepared it, the evidence behind it — the departure record, the cure plan with the PM's reasons, the issuer evidence, the pre-trade check of released orders — and the outcome: projected 80.6%, other limits within. He signs, or returns it with a reason.
Prepared by Rachel Adeyemi · signs Thomas Brennan, Fund CCO (the maker cannot sign).
The Records & Filing agent drafts the Q3 report to the board: the program, results at September 30, the three departures and their cure plans, the EU range and local names, and the certification. It already says that the portfolio manager accepted 4 of six proposed trades and that the projected result is 80.6%. Form N-PORT names items for 83 US funds are ready from approved tests for the treasurer, and the evidence pack exports per fund and quarter.
“Sent to the board portal only after the CCO signs.”
The same departure, seen by five of the people who carry it — the analyst, the CCO, the portfolio manager, fund counsel and EU product compliance.
Eight agents map, test, check, read the issuers, plan the cure and check every language; people approve, decide and sign.
Splits each fund name, in every market it is sold under, into terms; classifies each as brand, investment type, industry, region, characteristic, ESG or tax-exempt; finds its definition in the prospectus or SAI; and writes the data rule with the sentence it came from. It flags definitions that are not plain English or differ across trusts.
Computes each term's basket as a share of assets — positions from portfolio accounting, derivatives at notional, the security master and ESG data — every night, at quarter end, before every order and after large flows.
Recomputes every failing and near-line result by an independent method on a separate data snapshot, and shows its agreement on the meter.
When a vendor change or a data gap moves a meter, reads the issuer's own annual or sustainability report in its language, sets the original beside the English with the page, and compares it with both ESG data vendors.
Opens the departure record, runs the 90-day clock with the firm's milestones, and proposes cited trades from the portfolio manager's approved buy list, each checked against every other term and limit — region, bond share, duration, liquidity and issuer concentration.
Applies the ESMA thresholds, the Paris-aligned or Climate Transition exclusions each term category brings and the sustainable-investment minimum to EU sub-funds and share classes, plus the MAS and FCA naming rules for those registrations.
Aligns each local-language name with the English word by word, checks it makes the same claim, and cites the registered document in that language.
Builds Form N-PORT-ready names items from approved tests, the quarterly evidence pack per fund, the cited board report draft and the records the rule requires.
Approves each test; the Fund CCO signs every exception. The agents propose; a named person decides.
A conversation runs beside every screen. Ask why a meter moved, which trades fix it or when the deadline is — every answer cites its source and opens the screen it came from.
Why did Sustainable drop?
Sustainable fell from 81.9% at quarter end to 77.4% after three vendor changes: Andina Advanced → Average on Oct 8 (−2.1), Bosphorus red flag on Oct 14 (−1.0), Nusantara red flag on Oct 16 (−1.4).
Which trades fix it?
Six trades restore 82.1%; T1–T4 alone restore 80.6% and keep the cash for the Oct 23 redemption. Ana decides each trade; compliance releases the orders.
Why can't you decide Nusantara?
Vendor A flags Nusantara for deforestation after an NGO report of Sep 30; vendor B has no flag; the issuer's own report says its land is certified but leaves a supplier concession open. I am 62% sure, below the 85% line, so a person decides. Treating it as out is the conservative choice and goes to the CCO.
When is the deadline?
Day 12 of 90. Plan due Day 15 (Oct 22), CCO review Day 30 (Nov 6), firm target Day 60 (Dec 6), board notice Day 75 (Dec 21), deadline Day 90 (Jan 5, 2027).
13 screens from the working solution, on its sample data. Pick one to see it large.
What the firm configures for its names program. Every change is logged, and threshold and agent changes need the Fund CCO's approval and show their impact before they apply.
| Setting | Default | Choose from |
|---|---|---|
| Regulatory threshold | 80% | Locked by regulation (Rule 35d-1 and the ESMA guidelines) |
| Firm buffer | 82% (board-approved Aug 13, 2026) | 80% to 86% in half-point steps; a change is submitted to the CCO with the terms it would move to watch |
| Pre-trade test | Warn below the buffer · block below 80% | Also blocks any non-basket buy while a fund is in departure |
| Cure clock | 90 days | Locked · milestones: plan Day 15 · CCO review Day 30 · firm target Day 60 · board notice Day 75 |
| Quarterly review | Due 30 days after quarter end | Formal review and board report |
| Large flow | Above 2% of net assets | Triggers a re-test of the fund within a minute |
| EU passive breach | Correct within 30 business days | Management company policy |
| When an agent asks a person | Below the agent's confidence threshold | Term Mapper and Issuer Evidence agent 85% · EU Names and Language agents 90% · set in Agents and models |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “typical” = published figures (SEC Release 33-11368, March 14, 2025 — compliance dates of June 11 and December 11, 2026, generally 90 days to return to compliance, nearly 70% of funds with fiscal year-ends from August to December; ESMA guidelines on funds' names using ESG or sustainability-related terms, May 14, 2024, and ESMA's study of 924 funds — 65% renamed; SEC Form N-PORT proposal of February 18, 2026) · “estimated” = our estimate. People, funds, issuers and figures named on this page are fictional — characters and sample data in the working solution (Quillfield Capital).
Names Rule compliance is proving that every word in a fund's name that suggests a focus — including ESG terms like “sustainable” — is backed by an 80% investment policy, defined in the prospectus, reviewed at least quarterly and restored, generally within 90 days, after a departure, as SEC Rule 35d-1 requires. Fund Names Rule Compliance tests each name term against its policy and holdings every night under SEC and ESMA rules, with eight agents that map, test, check, read issuers, plan the cure and check every language, while analysts approve and the Fund CCO signs.
Under the amended SEC Names Rule, a fund whose name suggests an investment type, industry, region or characteristic must invest at least 80% of its assets accordingly, define each such term in plain English in its prospectus, review the basket at least quarterly and count derivatives at notional. In the solution, the Term Mapper finds each term's definition and writes the data rule with the sentence it came from, and the Holdings Tester computes the basket every night, before every order and after large flows.
Fund groups with $1 billion or more in net assets had to comply by June 11, 2026, and smaller groups by December 11, 2026; an existing open-end fund moves to the amended rule with its first on-cycle annual prospectus update filed on or after that date. The solution shadow-tests funds not yet on the amended rule until their on-cycle update.
Generally 90 days from a departure under Rule 35d-1. The Cure Planner opens the departure record and runs that clock with the firm's milestones — plan Day 15, CCO review Day 30, firm target Day 60, board notice Day 75. It proposes cited trades from the portfolio manager's approved buy list with their effect on every term and limit; the portfolio manager decides each one, compliance releases the orders and the Fund CCO signs the departure record.
Yes. The EU Names agent tests each EU sub-fund and share class against the 80% threshold, the Paris-aligned or Climate Transition exclusions its term category brings and the sustainable-investment minimum, with MAS and FCA naming rules for those registrations. An exclusion hit is shown with the issuer's own evidence, and EU product compliance records any passive breach.
The Language agent aligns every local-language name with the English word by word and checks that it makes the same claim, citing the registered document in that language. In the working solution it checked 96 names in 7 languages and found an Italian name saying “per il Clima” where the English says “Transition” — a stronger claim that fund counsel takes up and the CCO countersigns.
The Records & Filing agent builds N-PORT-ready names items from approved tests, the quarterly evidence pack and a board report draft that cites every statement. The SEC proposed on February 18, 2026 to remove the names items from Form N-PORT and moved their compliance date, so the items are kept ready rather than shown as due; the treasurer files and the CCO signs.
Yes. Agents never trade, file, send, rename, change a definition, approve a test or settle a disagreement, and below their confidence threshold they ask a person. The Agentic Solution Engine builds and deploys it from your requirements and documents — your prospectuses, buy lists and systems of record — and it goes live once every quality gate has passed.
Every 15(c) answer cited and checked against last year, ready 10 days before the deadline.
1-min demoFee BenchmarkingEvery peer fee your board sees, cited to the peer’s own fee table and signed.
1-min demoFund Launch ManagementFirst NAV on the planned date: every slip caught early, re-planned and signed off.
1-min demoWe'll run Fund Names Rule Compliance on your own fund names, prospectuses and holdings.