November 21, 2019
The rule seems to be borne of the idea that proxy advisory firms have too much influence, but without a lot of consideration for why they have influence. The 2003 rule (requiring investment advisors develop and disclose proxy voting policies, and record and report all of their proxy votes) caused a lot of investment advisors to offload all of the work and compliance effort onto someone else: namely the handful of proxy advisors that are equipped to do it.
Creating more rules to make compliance more difficult is only going to further entrench the very few proxy advisory firms we have to pick from. If the concern is about how much influence they have, then the response should be to give investment advisors greater choice by developing rules that encourage more proxy advisory firms to form.
The secondary concern seems to be handwringing over how often investors vote against management. Management already gets 98.2% support for their board nominees (https://law.rutgers.edu/sites/law/files/RR-1674-18-R.pdf). If that's too low, then you should probably change the wording of the mission of the SEC from "protect investors" to "protect the managers of companies".