N-PX: Our Three Main Takeaways (and things you may want to consider in advance of July 2025)

October 30, 2024

If you were involved in the latest round of Form N-PX filings, then you may have learned a thing or two about what goes into this updated process. We certainly did. While it’s still fresh on the mind, below are our key takeaways that firms may find useful as you consider what you may (or may not) want to do differently next year:

1. With N-PX, planning ahead goes a long way.
   • Given the large volume of data required to complete Form N-PX, firms may want to access the data through their proxy provider (if they have one) as soon as possible after the reporting period ends (July 1).
   • Make sure you have a solution in place for creation/conversion of Form N-PX into XML well before the end of the reporting period.
2. Access to data is equally as important as organization of data.
   • Make sure that their recordkeeping includes all required fields necessary for the creation of the updated Form N-PX (if you aren’t sure, feel free to reference our template).
   • If your solution does not provide access to all required data, create a plan to aggregate or include that missing data (i.e., FilePoint is happy to help populate missing data like vote categories).
   • Communicate with service providers to determine the best method of sharing that data for conversion (i.e., Excel, csv, XML, or another proprietary report formatting).
   • Firms that do not vote more than 50 meetings can consider maintaining that data in-house. Benefits of this include cost, formatting, and time to convert to XML.
   • For trusts filing with multiple series, we recommend reaching out to all advisers/parties in advance to ensure that they have their files formatted properly in the new format.
3. When it comes to filing, there are ways to simplify the process.
   • Locate your filing codes to avoid the hassle of tracking down your codes near the filing deadline.
   • With the new EDGAR Filer Access rule, beginning March 24, 2025, all existing filers will be able to enroll their organization using their CIK, CCC and passphrase up until the compliance deadline on September 15, 2025.
   • Enrollment in EDGAR Next is not required before the N-PX deadline on August 31, 2025, however, it is strongly recommended that you are able to locate your filing codes in order to submit any filings as well as enroll before the EDGAR Next compliance deadline on September 15, 2025.
   • If the data service provider is not filing, be prepared to file yourself or find additional support (in advance).
   • If you enroll before the compliance deadline, you will receive an updated CCC. In order for FilePoint to continue to file on your behalf, please notify us of your updated CCC or delegate filing authority to FilePoint in the dashboard in order for us to access your updated CCC.

Questions? We can help. Contact us today if you need guidance on your next N-PX filings.