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Shareholder Engagement and the Proxy Process.
This post is based on their Comment Letter in advance of the SEC's Proxy Process Roundtable.
We focus these preliminary comments on two primary areas, proxy advisory firms and the proxy process.
"It was better to deal with the issue in a dialogue, rather than through the proxy process".
Chairman Jay Clayton, Statement Announcing SEC Staff Roundtable on the Proxy Process (July 30 , 2018, available at https://www.sec.gov/news/public-statement/statement-announcing-sec-staff-roundtable-proxy-process/.
Members of the public may submit comments on the proxy process either before or after the roundtable occurs.
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This proxy processes mail in segments, and interleaves MIME parsing, decoding, decompressing and virus scanning.
Decisions on management of the proxy processes, service standards and related costs for administration of proxy voting constitute investor fiduciary acts that should be linked with implementation of fiduciary obligations.
These interventions, however, do not target neural processing directly but only via proxy-processes such as speech, behavior, and physiological indices (e.g. pulse and skin conductivity).
Accordingly, integrity and alignment of the proxy voting process are critical investor fiduciary concerns.
"It is imperative that our proxy voting process work," Mary Schapiro, chairman of the Securities and Exchange Commission, told the Practising Law Institute conference in New York.
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