Proxy Voting Considerations for Using Third-Party Vendors

September 2014


Investment advisers registered with the Securities and Exchange Commission (“SEC”) are not required, but have the option to vote proxies on behalf of their clients. Rule 206(4)-6 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) requires SEC registered investment advisers that have elected to vote proxies on behalf of their clients to adopt written proxy voting policies and procedures reasonably designed to ensure that votes are cast in the best interest of clients. Additionally, such policies and procedures must address how advisers handle conflicts of interest pertaining to proxy voting, provide information on how clients may obtain information on how the firm cast proxies on their behalf, and include an offer to provide the firm’s complete proxy policy upon request.

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