AIMA Workshop: Proxy Advisor Guidance


A recap of this workshop is available here.

On August 21, while many were enjoying the last week of summer, the SEC provided guidance in the form of two releases on proxy voting, one pertaining to investment advisers’ proxy voting responsibilities, and the other focused on the proxy voting “advice” itself and related voting service providers.

The releases are notable on many levels, one of which is that they were released as “guidance” versus formally adopted rules. On the adviser side, they have now set standards and expectations around advisers’ proxy voting process, which lays the foundation for actual rules in the future. On the service provider side, the guidance and interpretation have effectively designated proxy voting services as soliciting parties, posing further legal risk to these providers going forward and a likely outcome of increased costs.

What does all of this mean for you? During this workshop, we will discuss the practical implications of this guidance, with particular focus on what steps advisers can take now to ensure their activities align with the Commission’s expectations going forward. We will consider the legal relevance of the guidance-versus-rule approach to these releases, including the likely impact on those who choose to deviate from deviate from the express standards enunciated in the release. We also will review the potential for addressing any impractical aspects of this guidance before related rules are drafted.  

Questions may be submitted anonymously ahead of and during the workshop. Please note that your input will help us in forming a position regarding our advocacy/engagement efforts on this matter with the SEC and policy makers more broadly.

We hope you will join us for what we expect to be an informative and lively discussion on this important topic.


  • C. Dirk Peterson, Partner, K&L Gates LLP
  • Suzan Rose, Senior Advisor, Government & Regulatory Affairs, AIMA


Submitting your questions: 

We invite you to also submit your issues or questions, anonymously, ahead of this session for open discussion. This is an opportunity to frankly address your concerns while receiving practical advice and guidance on a non-attribution basis.

Submit your questions here

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