1. Division of Investment Management, Division of Corporate Finance, Proxy Voting: Proxy Voting Responsibilities of Investment Advisers and Availability of Exceptions from the Proxy Rules for Proxy Advisory Firms;citing Proxy Voting by Investment Advisors,2003
2. interpreting Section 206 of the Investment Advisers Act of 1940)). For further discussion of fiduciary obligations with respect to the proxy voting process, see Section VI;Sec;Capital Gains Research,1963