Deadline Approaching: Key Form N-PX Reporting Requirement For Investment Advisers

Understanding the new reporting requirement and its upcoming deadline is crucial for compliance.

There is a new reporting obligation pertaining to Form N-PX for investment advisers who are required to file a Form 13F with the SEC.

Historically, Form N-PX only applied to investment companies. However, new Rule 14Ad-1 under the Securities Exchange Act of 1934 (Exchange Act) requires institutional investment managers filing reports under Section 13(f) of the of the Exchange Act to report their say-on-pay and say-on-frequency proxy voting records for the 12-month period ending June 30th of the calendar year in which the manager made its initial Form 13F filing.

While these amendments to Form N-PX were adopted by the SEC back in November 2022, the first filing deadline stemming from these amendments is fast approaching.