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A July 15, 2011 CSFME letter to the Securities and Exchange Commission. The letter outlines recent systemic and technological advances enabling modifications to existing practices, which could permit broker‐dealers to vote proxies at the direction of currently disenfranchised, institutional, beneficial owners of lent securities (“Lender Directed Voting”). The letter further describes the numerous benefits lender directed voting could provide to a wide range of market participants.

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