Reporting of Executive Compensation Votes by Institutional Investment Managers


The American Sustainable Business Council (ASBC) supports a proposal that would increase the reporting of proxy votes by management investment companies such as mutual funds and exchange-traded funds (ETFs). ASBC understands that the proposal would also require institutional investment managers to report executive compensation votes or say-on-pay votes, of which ASBC is supportive. ASBC agrees with SEC Chair Genslers statement that, This proposal will make it easier and more efficient for investors to get crucial information about proxy votes from funds. ASBC is also supportive of enhancing the information contained in Form N-PX, which funds use to report about how they voted on proxy proposals related to investments they hold as ASBC agrees that as it stands today, it may be difficult for investors to analyze the forms. ASBC believes that the proposal would make funds proxy voting records more usable and easier to analyze, improving investors ability to monitor how their funds vote and compare different funds voting records.

The American Sustainable Business Council is the leading business organization serving the public policy interests of responsible companies, their customers and other stakeholders. Founded in 2009, ASBC membership represents over 250,000 businesses in a wide range of industries. ASBC advocates for policy change and informs business owners, policymakers and the public about the need and opportunities for building a vibrant, broadly prosperous and sustainable economy. We have recently launched a Corporate Transparency ESG Disclosure Working Group and ASBC would like to increase our engagement with the SEC to support your enhanced disclosure proposals and provide the business support for your policies around corporate transparency.The proposed rule, “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” follows Executive Order 14030, signed by President Biden on May 20, 2021. The order directs the federal government to implement policies to help safeguard the financial security of America’s families, businesses and workers from climate-related financial risk that may threaten the life savings and pensions of U.S. workers and families. | October 12, 2021

Subject: File No. S7-11-21
From: Ali-Reza Vahabzadeh
Affiliation: Vice President – Head of Membership, Chief of Staff, ESG Policy Co-Lead American Sustainable Business Council