Later this summer, the SEC will be holding  a Staff Roundtable on the proxy process.  This is a topic on which ABC has submitted many comment letters over the years.  

The announcement of the Staff Roundtable carried with it the opportunity to submit some preliminary ideas in regard to aspects of the Roundtable agenda.  Attached is ABC’s submission.  We refer to two past comment letters and add some additional words about technology and the rise of passive voting.

Regarding the latter, it is not too much to say that the growth of index funds – which is hardly news – has made the votes of index fund managers or their governance staff very significant indeed.  By extension, it has also added to the influence of proxy advisers on whom some of the index fund managers rely.