Institute Comments on SEC Burden Estimates Concerning Proxy Voting FilingWashington, DC, March 14, 2003 - The Institute believes the SEC has failed to effectively demonstrate that the collection of certain proxy voting information required by new Form N-PX meets the standards of the Paperwork Reduction Act, according to a recent comment letter. The Institute notes that the Commission: - has not demonstrated that the disclosure of fund proxy voting records is necessary for the proper performance of the Commission's functions;
- underestimates the burden of the collection of information by understating the costs (both direct and indirect) associated with disclosing proxy voting records and the hourly burden on the industry; and
- has failed to consider adequately alternatives that would achieve all of the Commission's policy goals.
The Institute recommends that the SEC withdraw Rule 30b1-4 and Form N-PX under the Investment Company Act and conduct an impact study to evaluate whether disclosure of fund proxy voting records is necessary to achieve the Commission's goals.
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