Reporting Requirements Applicable to Section 13(f) Institutional Investment Managers to Increase

November 11, 2010
Institutional investment managers who are subject to Section 13(f) of the US Securities Exchange Act of 1934 as a result of exercising investment discretion with respect to accounts holding certain US equity securities will soon see their reporting obligations extended. The SEC has proposed a new rule which, if adopted, will require such managers to report at least annually on Form N-PX how they voted on the proxies for the executive compensation-related shareholder votes of many US equity securities with respect to which the manager had or shared the power to vote. This update examines the requirements of this proposed rule.