On December 29, 2025, the American Institute of Certified Public Accountants (AICPA) Professional Ethics Executive Committee (PEEC) released an exposure draft proposing substantial revisions to its Code of Professional Conduct governing alternative practice structures (APS), which govern investments in accounting firms by private and public investors. The proposals represent the most significant regulatory development for private equity-backed accounting firms since PEEC first adopted APS guidance in 2000. This exposure draft follows a March 2025 discussion memorandum that resulted in the submission of 36 comment letters and extensive stakeholder engagement from accounting firm executives, state boards of accountancy, insurance liability carriers, accounting firms, academia, professional associations, and legal counsel for private equity sponsors.

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.