Proxy Vote Reporting: Considerations for Institutional Investment Managers as the Form N-PX Filing Deadline Approaches

New Rule 14Ad-1 under the Exchange Act – which becomes effective on July 1, 2024 – will require institutional investment managers subject to the reporting requirements of Section 13(f) of the Exchange Act (known as “13F filers”) to annually report on Form N-PX how they voted proxies relating to executive compensation (or “say-on-pay”) matters.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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