; (2) recommendations made in the prior fiscal year; (3) staff who reviewed and made recommendations on such proposals in the prior fiscal year (and the qualifications of such staff); and (4) recommendations made in the prior fiscal year where the proponent of such recommendation was a client of or received services from the proxy advisory firm. (m) Transparent policies Each registered proxy advisory firm shall file with the Commission and make publicly available its methodology for the formulation of proxy voting policies and voting recommendations. (n) Rules of construction Registration under and compliance with this section does not constitute a waiver of, or otherwise diminish, any right, privilege, or defense that a registered proxy advisory firm may otherwise have under any provision of State or Federal law, including any rule, regulation, or order thereunder. (o) Regulations (1) New provisions Such rules and regulations as are required by this section or are otherwise necessary to carry out this section, including the application form required under subsection (a)— (A) shall be issued by the Commission, not later than 180 days after the date of enactment of this section; and (B) shall become effective not later than 1 year after the date of enactment of this section. (2) Review of existing regulations Not later than 270 days after the date of enactment of this section, the Commission shall— (A) review its existing rules and regulations which affect the operations of proxy advisory firms; and (B) amend or revise such rules and regulations in accordance with the purposes of this section, and issue such guidance as the Commission may prescribe as necessary or appropriate in the public interest or for the protection of investors. (p) Applicability This section, other than subsection (n), which shall apply on the date of enactment of this section, shall apply on the earlier of— (1) the date on which regulations are issued in final form under subsection (o)(1)