On December 16, 2009 the SEC adopted rule amendments that enhance what information registered investment companies (“funds”) must disclose in proxy and registration statements, as well as Statements of Additional Information. The principal changes that will impact funds include expanded disclosure of:
- Director and nominee qualifications and prior directorships;
- Any legal proceedings involving directors;
- Whether a fund’s board considers diversity when nominating directors; and
- The board’s leadership structure and its role in risk oversight.
Funds with a fiscal year ending on or after December 20, 2009, must comply with the new disclosure requirements in all registration statements, proxy statements or post-effective amendments to an existing registration statement if filed on or after February 28, 2010. If these filings are filed prior to February 28, 2010 then compliance with the new requirements is not required for these filings until after the fund’s 2010 fiscal year-end.