SEC Issues Guidance Releases Related to Proxy Voting Responsibilities of Investment Advisers and Other Proxy Voting Issues

On August 21, 2019, the Securities and Exchange Commission published two separate releases related to proxy voting issues.  One release provided guidance regarding proxy voting responsibilities of investment advisers under the Investment Advisers Act of 1940 and Rule 206(4)-6 thereunder (the “Investment Adviser Proxy Guidance”), while the other provided an interpretation and related guidance regarding the applicability of certain rules under Section 14 of the Securities Exchange Act of 1934 to proxy voting advice (the “Exchange Act Proxy Guidance”).

A closer look at issues raised in these releases, along with some key takeaways, can be found in the following Mayer Brown Legal Updates:

Legal Update on Investment Adviser Proxy Guidance (authored by Leslie Cruz, Adam Kanter and Stephanie Monaco):

https://www.mayerbrown.com/en/perspectives-events/publications/2019/09/sec-publishes-guidance-on-the-proxy-voting-responsibilities-of-investment-advisers

Legal Update on Exchange Act Proxy Guidance (authored by Robert Grey, Michael Hermsen and Laura Richman):

https://www.mayerbrown.com/en/perspectives-events/publications/2019/08/sec-issues-guidance-on-the-application-of-the-proxy-rules-to-voting-advice

If you have any questions about the issues raised in these Legal Updates or would like assistance with SEC regulatory or other matters related to proxy voting, please contact any of the aforementioned Legal Update authors above or any member of our Investment Management practice.