November 18, 2021
I generally support the rule.
I agree the form should be tagged. This will allow broader used of the information. I also think the SEC should make all the data available for the reporting period available for the entire fund industry in one file in early September each year. It is tedious to mine this information from EDGAR.
The template used to visualize the filing on EDGAR should be made to look the way the form looks today, rather than the ridiculous approach taken with N-Port where each entry and set of questions is listed in a serial fashion.
Asset managers and funds should not share a form, or should use a different form types. Also, consider, like N-PORT, making each series file the info separately. Otherwise filings for trusts such as Ishares will be tediously long and unusable.
I also question the use of the XML format. Why can't funds just be given an excel template to fill out? The SEC loves to make filing as tedious as possible and that really only benefit the filing agents and passes costs on to investors.
I would also not focus so heavily on say-on-pay. There are plenty of good issues listed in N-PX, and the Commission seems to think that investors are ore concerned about say-on-pay that other issues. My guess is because it rhymes.
Perhaps the summary page should summarize how the fund voted on the listed categories instead of focusing on say-on-pay.