SEC Provides Guidance on Proxy Advisory Firm Use and Conflict Disclosure Obligations

Summary: On June 30, 2014, the SEC issued Staff Legal Bulletin No. 20 (IM/CF) (SLB No. 20), providing guidance to investment advisors on their proxy voting responsibilities and the use of proxy advisory firms, and setting forth conflict-of-interest disclosure obligations for proxy advisory firms. SLB No. 20 includes 13 Q&As that touch on many of the concerns raised in the SEC’s proxy advisory firm roundtable in December 2013.