September 30, 2021
While this rule making applies to form N-PX my comment slightly falls outside of its scope. However, it seems the burden of classifying a voting item should fall on the company not the voter and thus the classification should be listed alongside the description in the proxy statement. This would solve two problems. First, eliminating incremental labor on EACH voter required to submit form N-PX, instead only requiring incremental effort a single time from the reporting company AND giving the company a chance to frame the vote the way they see most relevant by their choice of category. Second, consistency in classification. If the votes are classified by the investors the data sets will most likely be uncoordinated and would not allow for cross sectional analysis. In order to allow for cross sectional analysis voters would have to coordinate their classification of votes which would require a monumental and costly communication effort. This would most likely also impact voting decisions for the sake of reduced costs. The actual result will be data that is simply incomparable across investors. While this would be a step forward in terms of providing transparency on when investors change their mind it leaves a lot of valuable information on the table that could be gained by cross sectional analysis.
In short: the proxy statement should be required classify the type of issue a voting item will reported under from a standardized list and the form N-PX should record the votes and their classification in order to unify the data set and allow for both time series and cross sectional analysis.
This would better serve the investing community and create significantly more valuable insights relevant to the purpose of the rulemaking.