On January 10, 2014, WLF filed formal comments with the SEC regarding use of proxy advisory services (PAS) firms by fiduciaries such as investment advisors and institutional investors. WLF expressed concern that reliance on such advisory firms, while ostensibly designed to protect the interests of shareholders, is generating burgeoning investor-relations costs to address social issues unrelated to shareholder return on investment. WLF argued that the PAS firms’ misbegotten advice on time-consuming shareholder proposals distracts attention and drains resources away from productive activities. WLF argued that, if this SEC-produced situation is to continue, it is incumbent on the SEC to exercise greater oversight in order to curb conflicts of interest, improve the factual accuracy of reports, enable companies to understand the standard against which they are being judged, and allow PAS firms to better tailor their recommendations to specific companies.