Proxy Voting

After achieving 100% of its planned milestone’s last year, the SEC’s Division of Investment Management is actively moving on a number of priorities comprising its ...

Another aspect of proxy voting that I am interested in is thresholds for submission and resubmission of shareholder proposals. It is important to achieve a ...

A day-long meeting Nov. 15 before SEC commissioners recounted a litany of problems around proxy voting and sprinkled potential solutions that may ultimately lead back ...

With this pending Roundtable and other policy considerations in mind, the staff of the Division of Investment Management has recently re-examined the letters that the ...

Some two weeks after a new group urged the Commission to tamp down on the administrative state (IA Watch, Aug. 30, 2018), SEC Chairman Jay ...

    Securities Exchange Act of 1934 – Rule 14a-8 Asia Pacific Fund-Omission of Shareholder Proposal Submitted by Matisse Capital Management, L.P. July 20, 2018 ...

We are unable to concur in your view that the Fund may exclude the Proposal from the Proxy Materials under Rule 14a-8(i)(3). We do not ...

We are unable to concur in your view that the Fund may exclude the Proposal from the Proxy Materials under Rule 14a-8(i)(3). We are unable ...

We are unable to conclude that you have demonstrated objectively that the proposal is materially false or misleading, including by impugning the integrity of the ...

We need to ask if our rule set has kept pace. For example, increasingly, a second layer of separation between ownership and control has ...