Statement Regarding Staff Proxy Advisory Letters

As recently announced, the Commission staff will be hosting an upcoming Roundtable on the Proxy Process.1 The Roundtable, which is expected to be in November 2018, will provide the staff an opportunity to engage with market participants on topics including the voting process, retail shareholder participation and the role of proxy advisory firms. In developing the agenda for the roundtable, the staff has been considering (among other topics) whether prior staff guidance about investment advisers’ responsibilities in voting client proxies and retaining proxy advisory firms should be modified, rescinded or supplemented. Staff guidance is nonbinding and does not create enforceable legal rights or obligations.