November 8, 2010
This doesn't serve any justifiable purpose and is a waste of time. It will cost a huge amount of time and effort to verify meaningless information and eventually harm investors as shareholders are more easily targeted by management. The fact is that shareholders vote over 90% of time with management--because they agree with management the vast majority of the time. Knowing how one small owner voted 1000 shares would not add any value that comes close to justifying the huge forced expense on the industry to comply with this proposal. We have almost 4,000 seperate accounts and assuming 80 proxies per year would mean 320,000 potential different data points. Yes, some are aggregated and we do some of work anyway, but this new regulation also comes with the onerous verification efforts of filing SEC documents under severe penalty if we get it wrong. Instead of forcing ten of thousands of 13F filing parties to produce and verify meaningless information, the proposal should be simply scrapped or, at most, only pertain to 13G/D filers (more than 5% owners).