Rule 206(4)-6 requires a registered adviser with voting authority over client securities to adopt and put into effect written procedures that can reasonably be expected to see proxies voted in clients' best interest, including how material conflicts of interest are addressed, to disclose to clients how they can obtain information about how their securities were voted, and to describe the policies and give a copy on request. Rule 204-2(c)(2) requires the policies, proxy statements received, votes cast, client requests and the records of the adviser's analysis to be kept for five years. The SEC's 2019 guidance addresses oversight of proxy advisory firms.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.