SEC Staff Withdraws Two No-Action Letters Related to Proxy Advisory Firms

September 18, 2018

On September 13, 2018, the SEC’s Division of Investment Management issued a notice indicating the withdrawal of two 2004 no-action letters that provided guidance on adviser responsibilities in voting client proxies and the use of proxy advisory firms.

The Division of Investment Management said it reexamined the no-action letters in light of the upcoming SEC roundtable discussion on “the proxy process” expected to be held in November 2018. The staff stated that the withdrawal of the letters would facilitate the discussion at the roundtable.


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Compliance, Exchange-Traded Funds (ETFs), Investment Advisers, Investment Companies, Mutual Funds, Regulatory