In 2020, the SEC required proxy advisory firms to (1) make proxy voting advice about a company available to the company in advance of or concurrently with disseminating it to their clients and (2) have a mechanism for making clients aware of the company’s response statement before they vote. In 2022, the SEC adopted amendments to remove these notice-and-awareness requirements. On June 26, 2024, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit ruled in National Association of Manufacturers et al. v. U.S. Securities and Exchange Commission that the SEC acted arbitrarily and capriciously in removing these requirements, and therefore violated the Administrative Procedure Act.