---
title: "Compare a fund's holdings with the focus its name suggests"
url: "https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/test-a-fund-s-esg-screens-and-exclusions-against-its-holdings/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A48-D20261018-1-US"
practice_area: "Climate, ESG & Sustainability Reporting"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Compare a fund's holdings with the focus its name suggests

> List the fund's name, the words in the name that suggest an environmental, social or governance focus, and each holding the portfolio file labels as inside or outside that focus, with the source.…

Canonical page: https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/test-a-fund-s-esg-screens-and-exclusions-against-its-holdings/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Climate, ESG & Sustainability Reporting](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List the fund's name, the words in the name that suggest an environmental, social or governance focus, and each holding the portfolio file labels as inside or outside that focus, with the source. Do not say the name is deceptive. |
| What the lawyer must review | 17 C.F.R. § 270.35d-1(a)(2) treats as materially deceptive or misleading a name suggesting that a fund focuses on investments with particular characteristics, and it gives as an example terms indicating that investment decisions incorporate one or more environmental, social or governance factors, unless the fund has adopted a policy to invest, under normal circumstances, at least 80 percent of the value of its assets in accordance with that focus, the policy is fundamental or shareholders get at least 60 days' notice of a change, and the terms match plain English or established industry use. The 80 percent test applies at the time of investment, with at least a quarterly review of the 80 percent basket and, in the circumstances the rule states, a return to compliance as soon as reasonably practicable and within 90 consecutive days. Paragraph (c) says a name may still be materially deceptive or misleading even if the fund adopts and follows that policy. The rule's definition of fund is a registered investment company or a business development company, including a separate series. You decide whether a holding is in the basket. The tool does not. |
| Written for | United States |
| Applies to | [Test a fund’s ESG screens and exclusions against its holdings](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/test-a-fund-s-esg-screens-and-exclusions-against-its-holdings.md) |

## Checking plan

- What the AI does: List the fund's name, the words in the name that suggest an environmental, social or governance focus, and each holding the portfolio file labels as inside or outside that focus, with the source. Do not say the name is deceptive.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Temporary departures for a launch, a reorganisation, a liquidation or a noticed policy change are in § 270.35d-1(b)(1)(iii). Do not treat every dip below 80 percent as a breach.
- Records of the 80 percent basket are kept for at least six years under paragraph (b)(3), the first two years in an easily accessible place. The tool does not create that record.

## Sources

- [17 C.F.R. § 270.35d-1, investment company names](https://www.ecfr.gov/current/title-17/chapter-II/part-270/section-270.35d-1) (checked 2026-10-22)
- [ABA Model Rule 1.1, Competence](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_1_competence/) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*