News & Analysis as of

Voting Requirements No-Action Relief

Eversheds Sutherland (US) LLP

And now for some good news - SEC no-action position provides limited relief for fund in-person voting requirements

On February 28, 2019, the Chief Counsel’s Office of the Securities and Exchange Commission’s Division of Investment Management issued a letter stating its no-action position regarding certain in-person voting requirements...more

Perkins Coie

SEC Staff Relaxes Certain In-Person Board Voting Requirements for Registered Investment Companies

Perkins Coie on

The SEC’s Division of Investment Management has relaxed certain in-person voting requirements for fund boards, subject to certain conditions, in a no-action letter to the Independent Directors Council (the IDC) issued on...more

Morgan Lewis

SEC Staff Relieves Fund Boards of Certain In-Person Voting Requirements

Morgan Lewis on

The US Securities and Exchange Commission staff provides new no-action relief to fund boards of directors from in-person voting requirements under certain circumstances....more

Dechert LLP

SEC Provides No-Action Relief from Certain Fund Director In-Person Meeting Requirements

Dechert LLP on

The Staff of the SEC’s Division of Investment Management (Staff) has issued a no-action letter permitting a registered fund’s board of directors (board) in certain circumstances to meet telephonically, by video conference or...more

Dorsey & Whitney LLP

Shareholder Proposals Restricting Board/Management Access to Preliminary Voting Results May Be Excluded

Dorsey & Whitney LLP on

On January 6, 2017, the SEC Staff granted no-action relief that would allow companies to exclude shareholder proposals preventing management or the board from accessing preliminary voting results on uncontested matters prior...more

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