; (D) if such ombudsman is unable to resolve such complaints prior to the publication of proxy voting recommendations to clients, include in the final report of the firm to clients a statement detailing its complaints, if requested in writing by the company; and (E) provide to clients receiving proxy advisory firm recommendations— (i) information demonstrating that draft recommendations (other than recommendations relating to an issuer-sponsored proposal or recommendations consistent with that of the majority of the board of directors of the issuer) are in the best economic interest of shareholders; and (ii) a certification by the chief executive officer, chief financial officer, and the primary executive responsible for overseeing the compilation and dissemination of proxy voting advice that the draft recommendations (other than recommendations relating to an issuer-sponsored proposal or recommendations consistent with that of the majority of the board of directors of the issuer)— (I) are based on internal controls and procedures that are designed to ensure accurate information; (II) do not violate applicable State or Federal law; and (III) prioritize economic returns to shareholders. (2) Definitions In this subsection: (A) Data and information used to make recommendations The term data and information used to make voting recommendations — (i) means the financial, operational, or descriptive data and information on an issuer used by proxy advisory firms and any contextual or substantive analysis impacting the recommendation; and (ii) does not include the entirety of the proxy advisory firm’s final report to its clients. (B) Reasonable time The term reasonable time — (i) means not less than 1 week before the publication of proxy voting recommendations for clients, unless otherwise defined through a final rule issued by the Commission