January 31, 2003 the U.S. Securities and Exchange Commission (the "SEC") adopted new rules under the Investment Advisers Act of 1940, as amended (the "Advisers Act"), that require each adviser registered under the Advisers Act that exercises proxy voting authority over client securities to:

  • adopt and implement written policies and procedures reasonably designed to ensure that the adviser votes proxies in the best interests of its clients;
  • describe these proxy voting procedures to its clients and to provide copies of the proxy voting policies and procedures to clients upon request; and
  • disclose to its clients how they may obtain information on how the adviser voted their proxies.

The new rules are contained in SEC Release No. IA-2106; the adopting release is available at http://www.sec.gov/rules/final/ia-2106.htm