Skip to main content

Written by Robert Quinn
Founder and CEO

Institutional investment managers who file a Form 13f with the SEC will need to collate its proxy voting record to disclose how they voted on executive compensation, or so-called “say-on-pay” matter. The SEC will not require 13f filers to begin filing the new Form N-PX to disclose such data until August 31, 2024, but the filing will cover votes cast after June 30, 2023.

The Form 13f is a quarterly report filed by institutional investment managers who have discretion over $100 million or more of U.S. – listed securities. The SEC publishes a quarterly list of Section 13f securities.

While registered investment advisers will already have to keep records of their proxy voting pursuant to Rule 206(4)-6 of the Investment Advisers Act of 1940, as amended, the Form N-PX will be a new filing obligation via EDGAR.

Managers who are not registered investment advisers will need to consider implementing policies and procedures to cover the key elements of Form N-PX, which include:

  • Votes to be disclosed — All “say-on-pay” votes, including: 1) periodic votes on the approval of executive compensation, 2) votes on the frequency of such say-on-pay votes, and 3) votes to approve “golden parachute” compensation in connection with mergers and acquisitions. These proxy votes are limited to those subject to the requirements of rule 14a-4 under the Securities Exchange Act of 1934, (i.e., an SEC proxy card is available for the matter).
  • Investment managers covered. Any institutional investment manager that (1) has the power to vote, or direct the voting of, a security; and (2) “exercises” this power to influence a voting decision for the security.
  • No exceptions. The rules do not contain a de minimis exception for smaller holdings or an exception for managers that do not vote proxies as a matter of policy.


All courses are accessible on our bespoke web or app platforms immediately upon purchase.



All courses are delivered through fully-automated, interactive online visual solutions.



Courses cost from as little as £20 per Learner per Course, or £6 per Learner on Subscription.



A certificate is issued on successful completion of all courses for compliance-filing and all UK courses are CPD-certified.



All courses include regular ‘Check Your Knowledge’ sections throughout and an end-of-course Quiz.



Courses take from 30 to 90 minutes to complete and can be viewed and completed in multiple sittings.


Purchasing, Onboarding & Volume Discounts

You can purchase any combination of our broad range of e-Learning courses and onboard multiple users in your Firm, in just four quick and easy online steps:

  1. Select the courses and add them to your Basket
  2. Checkout and purchase your course(s)
  3. Sign In and Register your relevant employees/Users
  4. Allocate all your registered employees/Users to their course(s)

We’ll help you connect the dots with clear prompts and assistance throughout this quick and easy four-step process, which includes applying automated Volume Discounts depending on the number of courses you purchase, as follows:

Number of courses Volume Discount
10 – 24 Courses 2.5% Discount
25 – 49 Courses 5% Discount
50 – 99 Courses 7.5% Discount
100 – 149 Courses 10% Discount
150 – 199 Courses 12.5% Discount
200 – 249 Courses 15% Discount
250 – 299 Courses 17.5% Discount
>300 Courses 20% Discount

You will receive an enrolment email for each Course you sign Users up to.

Once registered and enrolled onto their course(s), your employees/Users will each receive a welcome email inclusive of their login credentials/instructions together with a separate enrolment confirmation for each of their courses.

All Clients have access to a centralised User Dashboard with Live Reporting on the progress of all your enrolled employees/Users and from where you can download all your employees/Users Course Certificates once they have successfully completed their courses. This is clearly explained in our Power User Guide, downloadable from your Account.