Partner Aaron Morris submitted a written comment to the Securities & Exchange Commission in connection with a proposed rule change amending Section 302.00 of the NYSE Listed Company Manual to exempt closed-end funds from the annual shareholder meeting requirement.(File No. SR-NYSE-2024-35.) The comment, provided below, argues that the annual meeting requirement is an essential element of corporate democracy and a primary check on the adviser’s control over a fund. Elimination of the requirement would cause incalculable harm to investors and the marketplace generally, and is not justified by the limited cost savings that may be achieved by not holding a meeting.
