Mapping the Landscape of Comments to the SEC’s New Proxy Rules

In November 2019, the Securities and Exchange Commission (“SEC”) issued a notice of proposed rulemaking aimed at the roles played by proxy advisers in providing information and voting recommendations to clients. The move was preceded by substantively similar interpretive guidance used by the SEC in August 2019,  which itself attracted strong opposition (including a lawsuit).[1] As a regulatory byproduct of the rulemaking approach, however, the interested persons were afforded the opportunity to submit comment letters to the SEC.

That process ended on the February 3 deadline,[2] with more than 500 comments submitted. While this number is modest compared … Read more