Advisers

FYI: SEC Issues Proxy Voting Guidance for Advisers

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FYI: At its open meeting today, the SEC voted (3 to 2, Commissioners Jackson and Lee voting ‘no’) to publish guidance regarding the proxy voting responsibilities of investment advisers under Advisers Act Rule 206(4)-6 and related registration and reporting forms under the Investment Company Act. It is worth noting that the SEC has been discussing proxy voting issues from many angles for quite some time. Importantly, last fall, the Division of Investment Management withdrew two previously issued no-action letters — Egan-Jones Proxy Services (May 27, 2004) and Institutional Shareholder Services, Inc. (Sept. 15, 2004) — addressing advisers’ use of proxy […]