The recently approved SEC Proxy-Advisor Guidance and Interpretation and Guidance on Proxy Voting Advice were published in the Federal Register.
The two SEC documents, which went into effect September 10, 2019, provide (i) guidance on an investment adviser's responsibilities in proxy voting, and in vetting any advice that the adviser may itself receive from a proxy-advisor; and (ii) an interpretation and related guidance on rules for the solicitation of proxies and proxy voting advice.
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