On Sept. 29, the U.S. Securities and Exchange Commission proposed Rule 14Ad-1, which would require institutional investment managers subject to Section 13(f) reporting requirements to annually disclose their proxy votes on executive compensation matters. Currently, only registered funds are required to disclose their say-on-pay votes. If the rule is adopted, the universe of managers required to disclose their compensation votes would significantly broaden and would include many private fund managers for the first time.

In this Law360 article, partners Marc Elovitz and Kelly Koscuiszka and special counsel Adriana Schwartz discuss the potential implications of the proposed rule.