After literally many years of debate and heartache about what the SEC should do with proxy advisors, it comes down to a simplistic yet puzzling set of advisory comments.

We have weighed in a few different ways, finding that proxy advisors provide a private consulting service that falls beyond the scope of SEC regulation:

In Defense of Proxy Advisors

How Powerful are Proxy Advisors? 

Even More Debate on Proxy Advisors 

with our take on the hearing that led to the present rules:

How the Proxy Advisory Services Roundtable Should Have Gone.

Alas, no one listens to us. Instead, this week, the SEC issued a Staff Legal Bulletin on the subject. Some of it applies only to the proxy advisors (ISS, Glass Lewis), while some applies directly to RIAs. The RIA part is fairly harmless, but worth knowing about. The proxy advisor part has a bit more impact. And, Wachtell, Lipton gave us an unfortunate chuckle with their memo on the SLB.