Mich. Admin. Code R. 451.4.20 - Proxy voting

Rule 4.20. It is a fraudulent, deceptive, or manipulative act, for an investment adviser registered, or required to be registered, under section 406 of the act, MCL 451.2406, to exercise voting authority with respect to client securities, unless the adviser does all of the following:

(a) Adopts and implements written policies and procedures that are reasonably designed to ensure that the investment adviser votes client securities in the best interest of clients, which procedures must include how the investment adviser will address material conflicts that may arise between the investment adviser and its clients.

(b) Discloses to clients how they may obtain information from the investment adviser about how the investment adviser voted with respect to the clients securities.

(c) Describes to clients the investment advisers proxy voting policies and procedures and, upon request, furnishes a copy of the policies and procedures to the requesting client.

Notes

Mich. Admin. Code R. 451.4.20

2019 MR 1, Eff. 7/3/2019