The SEC recently adopted rule amendments that will revise certain proxy adviser practices and issued further guidance on investment adviser voting responsibilities in a welcome change for many public companies. In this update, we highlight key changes for proxy adviser reports, including:
- Proxy advisers must provide all public companies with a copy of their report at the same time it is given to their investment adviser clients.
- Proxy advisers must provide timely notification to their investment adviser clients of a company’s response to the report.
- Investment advisers must have procedures to ensure consideration of a company’s response to the report.