Comment Letter Reponsding to SEC’s Proposed Rule on Reporting of Proxy Votes on Executive Compensation by Institutional Investors

MFA submitted a letter today providing comments to the SEC on its proposal to require institutional investment managers to report how they vote proxies relating to executive compensation matters as required by Section 951 of the Dodd-Frank Act. In our letter we recommend that the SEC require a manager to report information only when it has instructed an intermediary to vote its shares, and to report, among other things, how the manager instructed the shares to be voted, rather than how the shares were actually voted.