<p><span>In September 2019, the Commission issued an interpretation and guidance addressing the application of the proxy rules to proxy voting advice businesses. <i>Commission Interpretation and Guidance Regarding the Applicability of the Proxy Rules to Proxy Voting Advice</i>, 84 Fed. Reg. 47,416 (Sept. 10, 2019) (“2019 Interpretation and Guidance”). On July 22, 2020, the Commission adopted amendments to Rules 14a-1(l), 14a-2(b), and 14a-9. <i>See Exemptions from the Proxy Rules for Proxy Voting Advice</i>, 85 Fed. Reg. 55,082 (Sept. 3, 2020) (“2020 Rule Amendments”). Those amendments codified the Commission’s view that proxy voting advice generally constitutes a “solicitation” as defined in Rule 14a-1(l), adopted Rule 14a-2(b)(9) to add new conditions to two exemptions from the proxy rules’ information and filing requirements that