SEC Dodd-Frank Implementation -- Proposed Institutional Investment Manager Reporting on Proxy Votes
On October 18, 2010, the Securities and Exchange Commission (“SEC”) proposed new Rule 14Ad-1 (the “Proposed Rule”) under the Securities Exchange Act of 1934 (the “Exchange Act”), as required by Section 951 of the “Dodd-Frank Wall Street Reform and Consumer Protection Act” (“Dodd-Frank”). If adopted as proposed, the Proposed Rule would require certain institutional investment managers, including hedge fund managers and pension fund managers that are required to file Form 13F, to annually file their record of proxy voting with respect to executive compensation shareholder votes. A copy of the SEC’s Proposing Release is available here.
