November 2, 2010
Please consider shortening the Form N-PX deadlines to a reasonably period after each meeting.
As it stands, if I vote shares in a company that I hold directly, I can learn the outcome of the vote within four business days after the meeting.
However, if I own the shares through an investment fund, I can learn the outcome of the meeting within four business days, but I will not know how I -- through the fund manager acting in my stead -- voted my shares until months later.
In late August when the funds report their voting records, I have to wade through huge volumes of unstructured information to learn how my funds voted the shares on my behalf at a particular meeting, something I personally have found extremely difficult to do.
There is little point in having these rules if they do not in practice inform fund owners about the voting actions of their funds. Shortening the deadlines would cut the amount of information fund owners have to process and give them access to voting results while they are still topical.
Most institutional shares are voted through the ProxyEdge electronic system, which already is used for vote disclosure to the SEC. Therefore, requiring institutional investment managers to report their votes on Form N-PX within four business days of each meeting is unlikely to be a burden on these managers.
I also support standardizing Form N-PX to use tagged data to make it easier for investors and intermediaries to find and analyze the voting records they are interested in.
Thank you for the opportunity to comment.