Recent developments suggest a potential inflection point in the proxy advisory landscape. JPMorgan Chase & Co.’s decision to discontinue the use of proxy advisory firms in favor of an internal, AI-driven voting platform, combined with escalating regulatory, legislative, and enforcement activity targeting the industry, signals heightened scrutiny of the role and influence of proxy advisors in U.S. capital markets. In this alert, we examine JPMorgan’s move, the broader regulatory and political backdrop, and what these developments may mean for plan fiduciaries, asset managers, and public companies navigating proxy voting and governance decisions in a rapidly evolving environment. 

This summary addresses recent legal developments regarding the use of forfeitures by 401(k) plans and related compliance issues raised under the Employee Retirement Income Security Act of 1974, as amended (ERISA).