SEC起诉要求ISS履行行政传票，调查其代理投票建议与投票数据合规资料提交

Institutional Shareholder Services, Inc.
U.S. SECURITIES AND EXCHANGE COMMISSION
Litigation Release No. 26632 / September 4, 2026
Securities and Exchange Commission v. Institutional Shareholder Services, Inc., No. 2:26-mc-00078 (E.D. Pa. filed Sept. 4, 2026)
SEC Files Subpoena Enforcement Action Against Institutional Shareholder Services Inc.
On September 4, 2026, the Securities and Exchange Commission filed a subpoena enforcement action in the U.S. District Court for the Eastern District of Pennsylvania seeking an order to compel Institutional Shareholder Services, Inc. (“ISS”), an investment adviser registered with the SEC, to comply with an outstanding SEC administrative subpoena.
According to the SEC’s application and supporting papers, ISS first refused to comply with routine requests from agency examinations staff and continues to refuse to fully comply with an administrative subpoena issued on July 21, 2026, by the Commission, ISS’s primary regulator. According to the SEC’s filing, the subpoena seeks documents highly relevant to its investigation of ISS’s compliance with the federal securities laws. ISS’s refusal to produce the required records to staff from the Division of Examinations, and now the Division of Enforcement, has impeded the Commission from advancing its mission and satisfying its statutory oversight and investor protection obligations, according to the filing.
The SEC’s Division of Examinations routinely obtains client information during examinations to ensure that registrants are complying with the federal securities laws, including determining whether investment advisers are acting in the best interest of their clients. As described in the SEC’s application, in March 2026, the SEC’s Division of Examinations began conducting an examination of ISS and requested data relating to ISS’s proxy recommendations and votes—the core of ISS’s business—that would enable the SEC to evaluate ISS’s compliance with the federal securities laws. However, according to the SEC’s application, ISS failed to produce the requested information in its possession, custody, and control, including after the SEC’s Division of Enforcement opened an inquiry into ISS’s failure to produce the information requested by the examinations team and issued a narrowly tailored administrative subpoena. The SEC’s application further states that more than four months have elapsed since the examinations team’s original request, and despite extended deadlines and repeated efforts by the staff to reach a resolution, ISS has continued to refuse to produce all of the requested materials.
The SEC’s filing requests that the Court enter an order compelling ISS to comply with the administrative subpoena.
The SEC is continuing its fact-finding investigation and, to date, has not concluded that any individual or entity violated the federal securities laws.