On August 21, 2019, the Securities and Exchange Commission approved two significant measures related to the increasingly large role of proxy advisory firms in the corporate voting process:
- It issued guidance to “assist investment advisers in fulfilling their proxy voting responsibilities, particularly where they use the services of a proxy advisory firm.”
- It issued an interpretation that proxy voting advice provided by proxy advisory firms generally constitutes a “solicitation” subject to the federal proxy rules.
We are preparing client memoranda with further details and analysis of both documents.
UPDATE: Our September 18, 2019, Client Memo discusses key aspects of the SEC measures and takeaways for investment advisers.