On January 23, 2026, the Securities and Exchange Commission (SEC) published a new compliance and disclosure interpretation in Question 133.02 that provides public companies with greater flexibility to condense the broker searches in connection with their stockholder meetings. Under this new interpretation, registrants may conduct the broker search less than 20 business days before the record date for the meeting, so long as the company reasonably believes that proxy materials will be disseminated to beneficial owners on time and otherwise complies with Rule 14a-13 under the Securities Exchange Act of 1934 (Exchange Act).

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.