D.C. Circuit Invalidates SEC’s Proxy Advisor Disclosure Rule, Finding Proxy Advisory Voting Advice is Not “Solicitation”
Date: 07/31/25
On July 1, 2025, in Institutional Shareholder Services, Inc. v. SEC (“ISS”), the U.S. Court of Appeals for the District of Columbia Circuit held that proxy-voting advice recommendations are not “solicitations” under the Securities Exchange Act of 1934, thus invalidating a Securities and Exchange Commission (“SEC”) rule requiring enhanced disclosure requirements for proxy advisory firms issuing proxy recommendations.
CGR Alert - D.C. Circuit Invalidates SEC’s Proxy Advisor Disclosure Rule, Finding Proxy Advisory Voting Advice Is Not ‘Solicitation’.pdf (pdf | 156.09 KB )