Institutional Investment Managers Must Prepare for Initial Form N‑PX Filing

Form N‑PX, which the SEC adopted in 2003, requires registered management investment companies to disclose publicly their proxy voting records on an annual basis. In 2021, the SEC proposed amendments to Form N‑PX to enhance the information reported and to require institutional investment managers to report how they voted proxies on shareholder advisory votes on executive compensation matters. It adopted those new requirements in November 2022. Initial Form N‑PX filings by institutional investment managers will be due by August 31, 2024. To assist covered firms in preparing for that impending deadline, a recent Seward & Kissel program discussed the key requirements of Form N‑PX, including which firms are covered, when filings are due, the information required, joint reporting and the availability of confidential treatment. The program featured Seward & Kissel partners Daniel Bresler and Paul M. Miller, as well as associate Joseph J. Nardello. This article synthesizes their insights. See “Adviser Sanctioned for Disclosure Issues and Inadequate Proxy Voting Policies” (Dec. 8, 2022).

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