SEC Takes First Step on Proxy Reform

On August 21, 2019, the SEC took the first step in implementing its previously announced agenda for proxy reform, issuing two releases aimed at improving the accountability of proxy advisory firms and the investment advisors who rely on them. In the releases, the SEC confirmed the proxy voting responsibilities of investment advisors and clarified that the federal proxy rules apply to proxy voting advice. The full text of the two SEC releases is available here and here, respectively, and the Sullivan & Cromwell memorandum summarizing the releases is available here.