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.

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