SEC Adopts Enhanced Proxy Voting Disclosure Requirements for Investment Funds and Requires Disclosure of “Say-on-Pay” Votes for Institutional Investment Managers

SEC Action Imposes Substantial Additional Reporting Obligations Sullivan & Cromwell LLP - November 21, 2022

On November 2, 2022, the SEC voted 3 to 2 (Commissioners Hester Peirce and Mark Uyeda dissenting) to adopt amendments to Form N-PX to enhance the information mutual funds, exchange-traded funds and certain other registered funds report about their proxy votes. In addition, the final rules will require disclosure on Form N-PX of how institutional investment managers voted on “say-on-pay” matters. The final rules will be effective on July 1, 2024, covering votes occurring on or after July 1, 2023.