Rules and Regulations
promulgated
under the
Investment Advisers Act of 1940
Rule 206(4)-6 -- Proxy Voting
If you are an investment adviser registered or required to be registered under
section 203 of the Act, it is a fraudulent,
deceptive, or manipulative act, practice or course of business within the meaning
of section 206(4) of the Act, for you
to exercise voting authority with respect to client securities, unless you:
Adopt and implement written policies and procedures
that are reasonably designed to ensure that you vote client securities in the
best interest of clients, which procedures must include how you address material
conflicts that may arise between your interests and those of your clients;
Disclose to clients how they may obtain information
from you about how you voted with respect to their securities; and
Describe to clients your proxy voting policies and
procedures and, upon request, furnish a copy of the policies and procedures to
the requesting client.
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