Proxy Voting and Disclosure Doesn’t Have to be Complex

Our research found that only one-third of RIAs say they have vote authority over client proxies, and some worry whether their policies and guidelines are in line with SEC requirements. Proxy voting and disclosure doesn’t have to be scary or complex. When you know your obligations and take advantage of trusted resources, you can easily and effectively add value for your clients.

What are my responsibilities?

According to SEC rule 206(4)-6, advisors who elect to exercise voting authority for client securities must:

• Draft and adopt written policies and procedures that are “reasonably designed to ensure that the advisor votes proxies in the ‘best interest’ of clients”.
• Create guidelines that address conflicts that may arise from time to time.
• Provide a concise summary of the firm’s proxy voting policies and procedures to clients.
• Make available, upon request, a copy of the policies and procedures used for voting and oversight.

What if I choose to outsource vote choices to a proxy advisory firm?

Some RIAs elect to follow vote recommendations of third-party proxy advisory firms, believing that outsourced decision-making alleviates potential conflicts of interest. If you choose to go this route, it’s nevertheless necessary to conduct a thorough, independent review of the relationship to meet your fiduciary obligations. Plus, you’ll still be required to ensure compliance with all of the SEC rule 206(4)-6 requirements above.

How can I comply with confidence?

Today, new and evolving technologies make it easy. Solutions like ProxyEdge are integrated with our Proxy Policies and Insights—an ideal combination for institutional investors and RIAs. These innovations provide intuitive access to voting trends and original data, delivering everything you need to create new voting guidelines. You can choose from an array of customizable templates, and cast votes based on industry insights, internal policies and third-party advisory recommendations.

With an agnostic platform like ProxyEdge, you’re able to conduct independent research and oversight. Once you establish policies and procedures, the platform automatically executes every vote. Compliance is simple and straightforward. You save time and enjoy total confidence knowing each vote aligns with client best interests.