SIFMA and SIFMA Asset Management Group (SIFMA AMG) submitted comments to the Securities and Exchange Commission (SEC) on a proposed rule Regulation E-Delivery. The proposed rule would permit covered entities to deliver required investor communications information electronically as the default method.
As noted in the letter, SIFMA strongly supports and has long advocated for a modernized framework that makes electronic delivery the default for investor communications, while preserving investors’ ability to choose paper delivery.
The proposed rule would better reflect how investors access information today, improve the timeliness and accessibility of important disclosures, and generate substantial savings that firms can use to invest in products, services, and technologies that benefit investors.
“SIFMA supports the SEC’s proposal to permit covered entities to make electronic delivery the default method for delivering covered information. This will result in significant benefits for covered recipients who increasingly prefer to access information electronically and substantial cost savings for covered entities and shareholders,” SIFMA stated in the letter.
SIFMA’s recommendations are intended to ensure the final rule establishes a practical and durable framework without imposing new implementation and ongoing compliance costs that could diminish those benefits. The letter recommends targeted changes that would allow firms of all sizes and business models to operationalize e-delivery more efficiently while continuing to protect investors and their privacy.
These include providing firms greater flexibility in using electronic addresses and delivering required information; aligning requirements across SEC and self-regulatory organization rules; preserving established householding and document-delivery practices; protecting investors’ electronic contact information from unnecessary disclosure to third parties; tailoring paper-delivery and opt-out requirements to retail customers; and avoiding duplicative policies, procedures and recordkeeping obligations. SIFMA also recommends recognizing the distinct needs of institutional investors by allowing them and their financial services providers to determine appropriate electronic delivery arrangements.
The full comment letter is available here.
Source: SIFMA
