HR3402-119

In Committee

To amend the Securities Exchange Act of 1934 to require certain disclosures by institutional investment managers in connection with proxy advisory firms, and for other purposes.

119th Congress Introduced May 14, 2025

Summary

What This Bill Does

This bill adds proxy-adviser disclosure duties to Securities Exchange Act section 13(f). An institutional investment manager that engages a proxy advisory firm and exercises voting power over covered equity securities must file an annual SEC report explaining how it voted on each shareholder proposal, the percentage of votes consistent with each retained proxy advisory firm's recommendations, how it considered proxy advice, how often it followed recommendations, how those votes reconcile with the fiduciary duty to vote in shareholders' best economic interest, how often votes changed because of errors or new issuer information, the degree of investment-professional involvement, and a certification that voting decisions were based solely on shareholders' best economic interest. Managers with at least $100 billion in assets under management must also tell customers in voting materials that shareholders need not vote on every proposal, perform an economic analysis before voting on shareholder proposals when not voting with an independent board majority recommendation, and include each analysis in the annual report. The bill defines best economic interest as maximizing investment returns over a time horizon consistent with fund objectives and risk management, and defines proxy advisory firm by proxy voting advice, research, analysis, ratings, or recommendations that constitute a solicitation.

Who Benefits and How

Shareholders benefit from annual SEC disclosures showing whether large managers follow proxy advisory firm recommendations and how votes serve economic interests. Corporate issuers benefit because managers must report how often votes changed because of errors or new issuer information. SEC investors using Form 13(f)-type data benefit from more information about proxy-voting processes and adviser influence. Customers of very large investment managers benefit from a notice that shareholders are not required to vote on every proposal.

Who Bears the Burden and How

Institutional investment managers using proxy advisory firms must prepare annual vote explanations, recommendation-alignment percentages, fiduciary reconciliations, and certifications. Managers with at least $100 billion in assets must perform and report economic analyses for many shareholder-proposal votes. Proxy advisory firms face more scrutiny because clients must disclose how heavily they rely on recommendations. SEC disclosure staff must receive and administer the new annual reports. Investment professionals may need to document their involvement in proxy voting decisions.

Key Provisions

  • Requires annual SEC reports from institutional investment managers that engage proxy advisory firms and vote covered equity securities.
  • Requires disclosure of vote explanations, proxy-adviser consistency percentages, fiduciary-duty reconciliation, vote changes, and investment-professional involvement.
  • Requires best-economic-interest certification for proxy voting decisions.
  • Adds customer notices and economic-analysis duties for managers with at least $100 billion in assets.
  • Defines best economic interest and proxy advisory firm for the new disclosure regime.

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.

At a Glance

What This Bill Does

Requires institutional investment managers that engage proxy advisory firms and vote covered equity securities to file annual SEC reports explaining shareholder-proposal votes, proxy-adviser alignment, fiduciary reconciliation, vote changes, investment-professional involvement, and best-economic-interest certification, with extra economic-analysis duties for managers with at least $100 billion in assets.

Key Policy Areas

Securities, Corporate Governance, Retirement

Primary Purpose

Requires institutional investment managers that engage proxy advisory firms and vote covered equity securities to file annual SEC reports explaining shareholder-proposal votes, proxy-adviser alignment, fiduciary reconciliation, vote changes, investment-professional involvement, and best-economic-interest certification, with extra economic-analysis duties for managers with at least $100 billion in assets.

Policy Domains

Securities Corporate Governance Retirement

Resolution provisions

Identified Gains
  • Shareholders
  • Corporate issuers
  • SEC investors
  • Customers of very large investment managers
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: ih
Shareholders:
SEC investors:
Corporate issuers:
Customers of very large investment managers:
Identified Costs
  • Institutional investment managers using proxy advisory firms
  • Managers with at least $100 billion in assets
  • Proxy advisory firms
  • SEC disclosure staff
  • Investment professionals
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: ih
Proxy advisory firms:
SEC disclosure staff:
Investment professionals:
Managers with at least $100 billion in assets:
Institutional investment managers using proxy advisory firms:

Legislative Progress

In Committee
Introduced Committee Passed
May 14, 2025

Mr. Loudermilk introduced the following bill; which was referred to …

May 14, 2025

Referred to the House Committee on Financial Services.

May 14, 2025

Introduced in House

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Financial Services
5 mentions across 1 clause
+1 positive -3 negative ?1 uncertain

Corporate issuers, Institutional investment managers using proxy advisory firms, Managers with at least $100 billion in assets

Positive-direction: Corporate issuers

Negative-direction: Institutional investment managers using proxy advisory firms, Managers with at least $100 billion in assets, Proxy advisory firms

Foreign Entities
1 mention across 1 clause
?1 uncertain

Shareholders

Government
1 mention across 1 clause
-1 negative

SEC disclosure staff

1/1
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Securities Corporate Governance Retirement

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology