On August 21, 2019, the Securities and Exchange Commission published two separate releases related to proxy voting issues.  One release provided guidance regarding proxy voting responsibilities of investment advisers under the Investment Advisers Act of 1940 and Rule 206(4)-6 thereunder (the “Investment Adviser Proxy Guidance”), while the other provided an interpretation and related guidance regarding the applicability of certain rules under Section 14 of the Securities Exchange Act of 1934 to proxy voting advice (the “Exchange Act Proxy Guidance”).

A closer look at issues raised in these releases, along with some key takeaways, can be found in the following Mayer Brown Legal Updates:

Investment Adviser Proxy Guidance: https://www.mayerbrown.com/en/perspectives-events/publications/2019/09/sec-publishes-guidance-on-the-proxy-voting-responsibilities-of-investment-advisers

Exchange Act Proxy Guidance: https://www.mayerbrown.com/en/perspectives-events/publications/2019/08/sec-issues-guidance-on-the-application-of-the-proxy-rules-to-voting-advice

If you have any questions about the issues raised in these Legal Updates or would like assistance with SEC regulatory or other matters related to proxy voting, please contact any member of our Investment Management practice.