The Securities and Exchange Commission's (“SEC” or “Commission”) recent staff roundtable on the proxy process, and its resulting guidance, interpretation and proposed rules on limiting the use of shareholder proposals, regulating proxy advisors and their creation of shareholder voting...

This comment letter to the SEC's staff roundtable on the proxy process requests the SEC to provide investment advisers with a liability safe harbor under the Investment Advisers Act of 1940 when using board voting recommendations in voting their proxies as long as their clients do not prohibit...