id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-9114	Dan Daskal	ISS and Other Proxy Advisory Firms' Conflicts of Interest: Analyzing the Insufficiency of New Securities and Exchange Commission Rules and Guidance	2022	53	.pdf	application/pdf	16886	762	46	PROXY ADVISORY FIRMS’ CONFLICTS OF INTEREST 1497 and, upon request, furnish a copy of the policies and procedures to the requesting client.39 While this rule served to bolster the nascent proxy advisory market, it also imposes continued responsibilities— stemming from their fiduciary duties40—on investment advisors who rely on proxy voting recommendations from proxy advisory firms. ICS markets its consulting services based on ISS voting recommendations, allowing the firm to increase profits by issuing negative recommendations for certain issuers.74 One commentator compared this to the rules “banning accounting firms from selling consulting services to companies they are auditing” and called on the Commission to “[p]rohibit proxy advisory firms from consulting with companies when they also make recommendations on voting issues for that company.	cache/cblr-9114.pdf	txt/cblr-9114.txt