• Skip to primary navigation
  • Skip to main content
Logo
Open search bar
  • About
    • Meet the Team
    • Todd Cipperman
    • Why Choose Us
  • Services
    • Money Managers
    • Registered Funds
    • Private Equity
    • Broker-Dealers
    • CyberSecure - Funds
  • In The News
  • Outsourced CCO
  • Client Engagement
  • Resources
    • Helpful Information
    • Regulatory Exams
    • Executive Interviews
    • Blog
    • Podcasts & Videos
    • Best Practices
  • Contact Us

Our Take Blog

Home
Our Take Blog
SEC Withdraws Letters that Allowed Advisers to Rely on Proxy Voting Firms

SEC Withdraws Letters that Allowed Advisers to Rely on Proxy Voting Firms

 The SEC has withdrawn two no-action letters that allowed an investment adviser to rely on third-party proxy voting services so long as the adviser had policies in place to ensure independence.  The SEC withdrew the letters because it wants to open debate about the regulation of proxy voting services at its upcoming Roundtable on the Proxy Process in November.  The SEC wants to consider whether investment advisers are “relying on proxy advisory firms for information aggregation and voting recommendations to a greater extent than they should, and whether the extent of reliance on these firms is in the best interests of investment advisers and their clients, including funds and fund shareholders.”  The SEC withdrew the Egan-Jones Proxy Services (5/27/04) and Institutional Shareholder Services (9/15/04) no-action letters.

OUR TAKE:  The Egan-Jones and ISS letters provided a de facto safe harbor for advisers to rely on third party voting services.  Their withdrawal and upcoming roundtable open the door to additional requirements on advisers to supervise proxy voting.

 

Back to Top
logo
480 E. Swedesford Road, Suite 220, Wayne, PA 19087
610-687-5320
LinkedIn Twitter
© 2020 Marlivia Properties LLC