SEC v. Institutional Shareholder Services Inc. (2013)
Settled
Checked against the primary document on October 3, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In 2013, the Securities and Exchange Commission settled an action with Institutional Shareholder Services Inc. over its failure to guard confidential client proxy-voting information, which an employee passed to a proxy solicitor in return for meals and event tickets. The release records a civil penalty of $300,000.
The record
| Agency | SEC |
|---|---|
| Release number | IA-3611 |
| Date filed | 2013-05-23 |
| Date resolved | 2013-05-23 |
| Status | settled |
| Criminal parallel | No |
| Defendants | Institutional Shareholder Services Inc. |
| Cited as charged or alleged | Advisers Act s.204A |
| Techniques |
What was ordered
- Civil penalty
- $300k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $300k
- Alleged gain
- —
What is alleged to have happened
the Securities and Exchange Commission announced this matter on May 23, 2013 as release IA-3611. The respondent named is Institutional Shareholder Services Inc. (1 entity). The Commission found that from about 2007 to early 2012 an ISS employee gave a proxy solicitor information on how more than 100 ISS clients were voting, in exchange for meals, concert and sports tickets and an airline ticket, and that ISS had no policies governing contact between its account managers and proxy solicitors. ISS consented to a censure, a cease-and-desist order under Section 204A of the Advisers Act and a $300,000 civil penalty.
The order is about safeguarding confidential client information, not about anyone trading on it, so this library no longer tags the matter as insider trading. No other technique fits, so it carries no technique tag.
For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.
Timeline
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.