SEC Issues No-Action Relief to Pacholder High Value Fund Regarding Proxy Proposal

January 18, 2013

The SEC staff issued no-action relief to the closed-end Pacholder High Value Fund, enabling the Fund to exclude a shareholder proposal from its proxy which asked for more disclosure by the Fund.  The SEC staff stated in its letter than the shareholder had failed to supply the Fund with the necessary proof that he had the minimum number of shares required under regulations to put forward a proxy proposal.  Among other things, the shareholder proposal had requested that the Fund’s shareholder reports include information on upgrades and downgrades in ratings, realized gains and losses exceeding 10% during the reporting period, and defaults experienced during the reporting period.  The Fund asked the shareholder to withdraw the proxy bid, noting in an earlier letter that it was already disclosing a large share of the information the proposal requested, in accordance with disclosure requirements.
Click here to access the no-action letter.


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