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AIST supports transparency and accountability regarding proxy voting, however, if implemented, the prescriptive nature of the detailed recommended disclosure regime and additional regulation on the ownership structure of proxy advisors would result in the undermining of trustees’ capacity to act in member’s best financial interest. Regarding independence, it is critical between a proxy advisor and the companies that they assess rather than between the proxy advisor and client. This is already in place in Australia. There is no evidence of systematic problems or material errors in the proxy voting service offerings in Australia, so it is unclear what regulatory failures the Consultation Paper is seeking to fix. Furthermore, the options outlined are out of step with practices in the USA and the UK.