On October 5, MFA and AIMA submitted joint comments in response to the Department of Labor’s proposed rules on proxy voting and shareholder rights. In the letter, we encouraged the Department to clarify that: (1) ERISA fiduciaries can comply with their obligations by adopting proxy voting policies that are consistent with the “permitted practices” set out in the rules; (2) SEC-registered investment advisers can satisfy their obligations under the proposed rules when the adviser complies with the SEC’s proxy voting rules, to the extent consistent with the Department’s permitted practices; and (3) ERISA fiduciaries and investment managers are not subject to additional documentation requirements with respect to specific proxy votes when they vote in accordance with appropriate policies and procedures.
