Voting Client Securities: Form ADV Part 2A requires disclosure of voting procedures if the adviser has authority to vote. If the adviser does not have authority, what must be disclosed?

• A. A brief description of voting procedures
• B. The adviser’s entire voting history
• C. The specific securities held by the client
• D. No disclosure is required

Answer: (A)

The main idea tested here is transparency about proxy voting under Form ADV Part 2A. Even when an adviser does not have authority to vote client proxies, the disclosure must still include a brief description of how voting would be handled—what procedures would apply if authority were granted or if the adviser were to vote in the future—so clients understand the firm’s approach to proxy voting. This helps provide clarity on whether and how votes would be cast, without needing to reveal every detail. The other options aren’t correct because the form does not require full voting histories or client security holdings, and saying no disclosure is required is not accurate since a concise description of voting procedures is still expected.