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The IAA discussed investment advisers’ use of proxy advisory firms for a range of services and that increased regulation of these firms would increase costs for advisers and their clients. The IAA also discussed advisers’ understanding of their obligations to vote proxies in the best interest of their clients.
The IAA recommended that the Committee focus on weaknesses in the infrastructure of the proxy system, and strongly objected to efforts to restrict advisers’ use of proxy advisory firms and to regulation that would make those services more expensive and increase barriers to entry.
We support the SEC’s proposal regarding proxy voting advice provided by proxy advisory firms and request that the SEC rescind both the 2019 and 2020 guidance for investment advisers on proxy voting.
The IAA recommended the SEC revise the proposed requirement to report shares loaned but not recalled for a say-on-pay proxy vote by a reporting person and instead require a narrative disclosure.
We support the DOL’s proposal related to ESG investing and proxy voting and recommend that the DOL remove certain ESG-specific language in the rule text and remove the proposed “collateral benefit” disclosure.
The IAA strongly opposed and urged the DOL to withdraw its proposal on proxy voting and the selection and monitoring of proxy advisory firms because it represents a significant departure on how plan fiduciaries view their proxy voting responsibilities, and would substantially increase compliance costs without providing measurable benefits to plan participants and beneficiaries.
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