March 20, 2019
I would like the SEC-IAC to take up a review of Title 17, Section 270.30b1-4 Report of Proxy Voting Record.
Any such review would find N-PX filings are not fit for purpose. Filings do not enable fund shareholders to monitor their funds involvement in the governance activities of portfolio companies. Filings do not shed light on mutual fund voting to illuminate potential conflicts of interest and discourage voting that is inconsistent with fund shareholders best interests. They do not enable shareholders to evaluate how closely fund managers follow their state proxy voting policies, and to react adversely to fund managers who vote inconsistently with these policies.
The SEC-IAC should recommend amendments to require real-time disclosures in a database format, which most fund can accomplish at virtually no expense by simply opening a narrow window onto their internet proxy voting platform.
I have attached a first rough draft to focus discussion.
Comments attached.
Attached File