SEC Withdraws Two No-Action Letters Regarding Use of Proxy Advisory Firms

The SEC on September 13 did something unexpected: It pulled two 2004 Division of Investment Management no-action letters concerning advisers use of proxy advisory firms in preparation for a planned November roundtable on the subject. What made the move unusual was not that the agency decided to supersede the letters, but that it did so by actually removing them, rather than simply issuing new guidance indicating a change of course.
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