August 31, 2004 marked the beginning of a new period for institutions, investment advisors and annuity companies. It's the turning point when disclosing proxy voting history transitioned from a best practice to an SEC regulated activity*.
Your decision about how your organization will comply with these disclosure rules should be based on a number of considerations. Beyond simply meeting the disclosure requirements are the matters of the time that may be required on your part to establish and maintain the process, and the integrity and accuracy of the vote history. You're probably not looking to dedicate more time or resources to these operational and compliance demands, which is why Broadridge developed ProxyDisclosure. We'll help you easily and accurately perform all the tasks that will help assure your compliance.
ProxyDisclosure is available today to provide vote history on the fund level, regardless of the method or provider of vote execution. And, getting started won't divert you from all the other responsibilities you already have. You don't have to coordinate the receipt of vote history files from your advisors.
ProxyDisclosure can be used alone as a reporting and compliance tool, or in conjunction with Broadridge's electronic voting and record keeping tool, ProxyEdge.
Affordable - Pay for just the level of service your firm needs, from vote history to SEC filing to web disclosure.
Efficient - Reduces the need to obtain vote history from various sources since Broadridge processes the majority of institutional votes.
Convenient - Log on from any internet-connected computer, 24/7, using your confidential user ID and password. Access user-defined information when required.
Aggregation of Votes - Broadridge's ProxyDisclosure product provides fund specific and/or account level voting records including votes cast by multiple underlying investment advisors or other third party entities.
Reporting - The reporting feature is appropriate for both advisors and investment companies, including those that use third-parties to execute voting. Users can run reports on a monthly basis or when needed. Multiple export format options report customization account details available for vote auditing
Third Party Vote Audit – Broadridge provides the ability to aggregate and report voting activity across multiple accounts at multiple custodians, whether voting is performed internally or by a third party.
N-PX Creation - Our service allows for the creation of the SEC form N-PX.
SEC Filer - Once the form N-PX is created, the user can elect for Broadridge to perform the filing directly with the SEC. Users will have the option to review the file prior to submission.
Web Disclosure - Broadridge will create a fund-branded website for disclosure of both fund voting activity and voting policies and guidelines. The site will enable investment companies to offer their underlying shareholders/investors direct access to proxy voting information in an environment seamless to their proprietary website.
* New Rule 30b1-4 under Investment Company Act of 1940.