US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275)
Sections 206 to 208 and the section 206(4) rules: antifraud, principal trades, marketing, custody, pay to play, proxy voting, compliance programmes, pooled vehicles – US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275)

US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275) 206-4-6-proxy: Adopt proxy voting policies reasonably designed to vote in clients' best interest, disclose them and keep the voting records

Rule 206(4)-6 requires a registered adviser with voting authority over client securities to adopt and put into effect written procedures that can reasonably be expected to see proxies voted in clients' best interest, including how material conflicts of interest are addressed, to disclose to clients how they can obtain information about how their securities were voted, and to describe the policies and give a copy on request. Rule 204-2(c)(2) requires the policies, proxy statements received, votes cast, client requests and the records of the adviser's analysis to be kept for five years. The SEC's 2019 guidance addresses oversight of proxy advisory firms.

Maintained by Gerard Blokdyk

Other controls in Sections 206 to 208 and the section 206(4) rules: antifraud, principal trades, marketing, custody, pay to play, proxy voting, compliance programmes, pooled vehicles – US Investment Advisers Act of 1940 and SEC Adviser Rules (17 CFR Part 275)

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