Rule 206(4)-6 would require investment
advisers to adopt and implement written policies and procedures
reasonably designed to ensure the adviser votes client proxies in
the best interests of clients, and disclosure these policies and
procedures to clients, as well as information how clients can
obtain information from the adviser about how the adviser voted the
client's securities.
US Code:
15
USC 80b Name of Law: Investment Advisers Act of 1940
We have increased the estimated
hour burden from 184,237 hours to 225,575 hours based on new
information with respect to the number of SEC-registered investment
advisers that would be subject to the collection of information.
This new information is based on data derived from information
submitted by advisers on Form ADVs filed through the Investment
Adviser Registration Depository (IARD). The number of responses per
investment adviser and the number of hours per response have not
changed since the last estimate. The increase in hour burden is
entirely due to an increase in the estimated number of
respondents.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.