SEC’s Highly Anticipated Guidance on Proxy Advisory Firms: First Analysis


This First Analysis article discusses the interpretative release and new guidance relating to the proxy voting process issued by the Securities and Exchange Commission (SEC) on August 21, 2019. The SEC adopted (1) guidance on the proxy voting responsibilities of investment advisers under the Investment Advisers Act of 1940 and related rules (the Advisers Guidance) and (2) interpretation and guidance on the applicability to proxy voting advice of the rules on proxy solicitation under the Securities Exchange Act of 1934 (the Solicitation Guidance).