June 22, 2023
More Say-On-Pay Transparency Coming
Late last year, Liz and John blogged about the new rules that will require institutional investment managers to disclose their say-on-pay votes on Form N-PX. This post on Latham’s Global Financial Regulatory Blog reminds Form 13F filers that they will need to file their first Form N-PX by August 31, 2024. The form will cover July 1, 2023 to June 30, 2024, so 13F filers must update their policies, procedures, and systems now to capture the required information starting this July. This also means, for issuers and investors, that we’ll have greater transparency next summer into managers’ voting decisions on say-on-pay proposals in the 2024 proxy season.
– Meredith Ervine