SEC Issues FAQs on Proxy Voting

Last week the Securities and Exchange Commission’s (“SEC”) Division of Investment Management issued new guidance on proxy voting in the form of a Legal Bulletin (the “Bulletin”) containing, thirteen (13) frequently asked questions. The guidance reiterates the importance of an adviser’s fiduciary duty to its clients as it relates to how a proxy firm votes client shares.

Highlights from the Bulletin for investment advisers are:

  • An investment adviser could demonstrate compliance by conducting a periodic review of sample proxy votes and an annual review of the adequacy of proxy voting policies and procedures




Please review the entire Bulletin to learn more about an investment adviser’s responsibilities in voting client proxies and retaining third party proxy firms.  

For further information on this and other related subjects, please contact us at or (619) 278-0020.

GENERAL DISCLAIMER: Information contained within this blog does not create a business-client relationship, and none of the content of this blog can be deemed to be consultive business advice.

Leave a Reply

Your email address will not be published. Required fields are marked *