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On August 21, 2019, the US Securities and Exchange Commission (SEC) published guidance on the proxy voting responsibilities of investment advisers under the Investment Advisers Act of 1940 and Rule 206(4)-6 thereunder (Investment Adviser Guidance). On the same date, the SEC also published an interpretive release regarding the applicability of certain rules under Section 14 of the Securities Exchange Act of 1934 to proxy voting advice (Exchange Act Guidance), which is the subject of a separate Mayer Brown Legal Update. This Legal Update, however, focuses on the Investment Adviser Guidance.
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