2026 Sample Examination Questions – Philadelphia – Proxy
This is a set of sample SEC examination questions from the Philadelphia Regional Office regarding the use of proxy advisory firms and proxy voting.
September 30, 2026
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Comments on DOL Proxy Proposal
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.
October 05, 2020
Comments on SEC Proxy Voting Advice Proposal
The IAA strongly opposed the Proxy Voting Advice proposal because there is no compelling evidence justifying the proposal. The IAA also highlighted the practical concerns with having issuers review proxy voting advice in advance and noted that the proposal would make it more difficult and expensive for advisers to vote proxies.
February 03, 2020
Comments on SEC Staff Roundtable on Proxy Process
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.
December 31, 2018
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.
December 06, 2018