Responses to ACSPC Request for Public Input
Question 26. Are the costs of preparing and distributing printed paper versions of proxy statements and annual reports to shareholders unduly costly for smaller companies? Describe the extent of such costs, and the amount that could be saved if the SEC allowed complete electronic delivery of documents.
The following answers have been received:
08/02/2005 17:44:12 There is printing and postage required that could be extensive based on the size of the documents. Electronic delivery would speed up the process as well. No time wasted on printing and mail delivery.
08/03/2005 01:39:17 This is not an issue for our company.
08/03/2005 07:01:34 have u seen the cost for printing and distributing this stuff???
08/03/2005 08:55:04 Yes, electronic would substantilly reduce printing and mailing cost for us as a smaller company and of cours would for bigger companies as well. However it impacts smaller much greater.
08/03/2005 10:40:26 Yes. Our company would save approximately $10,000 annually.
08/03/2005 12:17:58 great for companies. proxy statements for investors? grandma doesnt have a computer. not smart. same with doing away with certificates for shares. not smart.
08/03/2005 13:55:42 Paper CERTS do not need to done away with. Many long- term investors do not this to happen.
08/03/2005 15:01:40 I like the idea of electronic delivery. I am not sure we would use it since we currently send out more color printed information than required.
08/03/2005 15:22:49 Annaul Reports and Proxy statements are considered a cost in being a public or non public company. It cost us around $18 per sharehodler on an annual basis.
08/03/2005 18:01:35 Please look into item no 29
08/03/2005 18:30:29 x
08/03/2005 19:54:33 I have no opinion on this question.
08/04/2005 09:39:15 No comment
08/04/2005 10:40:16 Once we had 500 shareholders, our proxy requirements increased. It confused many of our long-term stockholders. We have provided financial statements with all disclosures for years but the additional proxy statement with required information about audit and nominating committees and ethic policies have increased the proxy to a book of its own. Since we have been a public company, the cost to provide our annual information to shareholders has increased by approximately 60%.
08/04/2005 12:09:05 With more information, less help from external auditors and short timeframes for filing, the time constraints are tremendous. When you factor the printing and mailing lead time...often a month...the true cost is in the time, moreso than the actual dollar costs. Allowing electronic delivery would be a tremendous savings and benefit to smaller companies. Plus, I think shareholders could much more easily retain this information than in current paper format.
08/04/2005 13:38:24 It doesn't have to be overly costly. It's a management decision.
08/04/2005 14:20:27 No, it is a small cost compared to SOX.
08/04/2005 18:05:44 No
08/05/2005 12:44:28 Complete electronic delivery would no doubt save costs, but I am not privy to what costs are currently being incurred.
08/05/2005 15:34:53 Not an issue to us - we did this before we were a SEC filer.
08/05/2005 15:43:46 In all circumstances for small bank financial reporting it would be most beneficial for the SEC to consider use in some form of the Call Report to eliminate redundant reporting. If SEC and the FFIEC could talk to each other it would be one of the significant events ...
08/05/2005 16:45:38 Yes, they are. Electronic filings should be sufficient, but they must be able to be electronically certified as fully accurate and un-editable by anyone outside the firm in anyway. This is an example where some sort of access control makes sense - ensuring the accuracy and safety of such documents in electronic form. The initial cost to implement such systems would be far outweighed by the costs of reduction in energy spent and paper wasted, saving the conomy billions of useless dead tree documents. That is Billions with a "B". That's real money. Storage media would have to be refreshed and reviewed every 7 years, but financial material could be more efficiently stored and backed up for safekeeping.
08/05/2005 19:33:08 It is really a matter of image. Clssy looking reports are costly while less expensive reports make the company look less attractive. electronic materials would be cheaper and look better.
08/06/2005 13:52:06 Electronic delivery is not yet an alternative to paper. Not everyone has the desired level of access to electronic delivery.
08/08/2005 11:10:11 yes and no
08/08/2005 11:39:29 It could save a great deal of money and effor if those documents could be sent electronically. All this information is available on our website. How many investors do not have access to the internet? I suspect some but a small percentage. I am sure something could be done to address their needs.
08/08/2005 14:06:10 Here is some expense associated with getting this information to investors but even in this day and age not everybody has access to a computer and e-mail etc., and such access should not be a requirement to receiving such information. The cost is what it is but I think it is necessary.
08/08/2005 15:43:24 No.
08/08/2005 21:39:10 Due to the Internet, it is a burden and somewhat illogical to require printed statements. Printed copies should be made available at the investor's request.
08/09/2005 09:30:31 Yes. Electronic delivery could save us 50% of our present costs.
08/09/2005 16:26:34 Clearly a significant amount would be saved, but I don't think the investment world is ready for that magnatude of change. A few more years yet...
08/09/2005 17:25:10 No.
08/10/2005 09:04:41 no comment
08/10/2005 13:44:39 Electronic delivery would be great for some but probably half of our shareholders would not be able to receive electronic forms...so limited help for us.
08/10/2005 16:00:18 No, we're fine with it.
08/10/2005 17:18:15 No - cost of being public.
08/10/2005 22:09:27 It depends on the organization. I think we went over board due to not fully understanding the minimums
08/11/2005 20:27:22 I believe that shareholders should be given the choice as to whether or not they want a glossy report. Personally I like them but there cost can be significant.
08/12/2005 13:12:10 No opinion.
08/12/2005 14:46:45 Not in our case
08/12/2005 16:35:01 We are presently soliciting proxies on a $500k issue at a cost of more than $100k. This makes little sense and, if asked, I believe investors would be enraged.
08/13/2005 12:39:43 Don't know
08/15/2005 13:08:27 Any cost that can be eliminated without reducing disclosure would be appropriate. Electronic delivery should be encouraged.
08/15/2005 14:27:30 I don't have numbers but the general concept of paper distribution of documents available on a Web side seems to me outmoded. It seems it does to the SEC as well, see Securities Offering Reform release.
08/15/2005 15:10:05 yes
08/15/2005 15:13:01 I would prefer that an electronic medium be acceptable. You will always have "Aunt Martha's" that don't have a computer and won't accept that medium. Again, we need to stop worring about the Aunt Martha's and start focusing on the institutional shareholders. These are the investors who are driving the markets and I believe that they would welcome this change.
08/15/2005 15:14:45 No, it is not especially costly if one where to provide a basic document. The cost is in the marketing and sales enhancementrs to the basic document. Electronic delivery would be great, and probably would decrease costs by about 30%, since a major portion of the expenses are related to delivery to street name companies.
08/15/2005 16:33:43 no-- a company does not have to spend that much to provide information to their shareholders- we certainly would welcome electronic delivery, but would still provide hard copies to those who request.
08/15/2005 16:41:14 Biggest cost is legal. Then printing and mailing. Only the latter would be eliminated with electronic delivery.
08/16/2005 09:51:21 No
08/16/2005 10:10:36 No.
08/16/2005 10:21:17 No.
08/16/2005 10:26:28 yes burdensome, yes electronic would be better, cannot quantify cost benefit, likely small for Acambis
08/16/2005 10:44:16 No.
08/16/2005 11:18:54 ok as is
08/16/2005 11:52:16 Not yet. As we grow it will become much more difficult to finance.
08/16/2005 12:15:34 We currently spend approximately $25,000 to print, file and send these types of reports. If this cost could be cut in half by electronic distribution methods, that would be great, but I would guess that many people still will prefer a paper copy.
08/16/2005 13:04:14 By using a 10-KSB wrap we have reduced the cost of preparing and mailing our annual report. However, the cost is still relatively high and the amount of paper we generate is alarming. We would save about $20,000 if we were able to just make the reports available electronically.
08/16/2005 13:12:04 Electronic delivery is not enough; many smaller and older investors do not have the IT expereice, knowledage or equipment necessary for such.
08/16/2005 13:19:29 No opinion.
08/16/2005 13:20:23 No. And we do both paper and electronic and the cost is < $100K per year. We pay 3X this amount on directors fees, so this is just "whining"
08/16/2005 13:25:32 The cost of the paper versions are not onerous, particularly if companies avoid ego-inflating copy. However, it is obsolete and unneeded. Any serious investor has already sprung for the cost of internet access, or can go to any public library. This is not a question of whether paper reporting should be dropped, but when!
08/16/2005 13:27:00 No.
08/16/2005 14:08:05 This hasn't been a big issue.
08/16/2005 14:23:10 The costs for SEC requirements are clearly disproportionatly higher for small companies. Electronic filing is a potential way to reduce costs. Most sophisticated investors are capable of accessing electronic documents. The SEC needs to make an enhancement to thier Edgar system so that documents are recoverable by the company ticker symbol.
08/16/2005 14:54:27 While in our case the paper costs are relatively small, electronic distribution would be faster and more effective.
08/16/2005 15:15:12 No. We have always gone the extra mile to insure that our shareholders have all the information they need and in so doing we consider the costs to reasonable.
08/16/2005 16:08:50 I do believe the costs for paper versions of filings are burdensome to smaller companies, but I do believe that electronic delivery or retrieval of documents should be allowed.
08/16/2005 16:16:04 The costs are not too significant for us and we believe the shareholders are entitled to this proxy and annual meeting.
08/16/2005 16:45:09 Paper is extremely expensive and an outdated mode of communication. We don't have precise costs but significant savings could be realized as well as improved communication.
08/16/2005 18:35:41 Not unduly costly to our company.
08/16/2005 21:29:07 No.
08/17/2005 12:28:22 Yes, extremely expensive and increasing. Printing and mailing costs are the biggest.
08/17/2005 12:36:00 These costs are very large and do burden smaller companies more than larger ones. I'd like to see an "opt in" option where shareholders who do not respond would not necessarily receive a full annual report and proxy--perhaps just the proxy card. The alternative could be provided electronically or in paper form upon request. The real cost savings could come from completely eliminating paper, but I don't see that as an acceptable option.
08/17/2005 12:48:33 IN 45 years of being aCEO of various public companies 6 people in total have showed up for Annual meetings. A lot of money was wasted on coffee and doughnuts.Makes no difference.
08/17/2005 16:18:39 The paper versions are unduly costly. Many shareholders throw them away without reading them at all. Any interested shareholder can obtain a copy electronically. We spend $50,000 per year for printing annual reports / quarterly reports / proxy statements.
08/17/2005 18:49:27 Even in teh electronic age I think paper documetns are very convenient for stockholders
08/17/2005 19:31:08 The cost are high. It would be much better to do something in electronic format. Our annual report printing and distribution costs exceed $30,000 annually.
08/17/2005 21:27:12 Yes. In total the cost for us is about $40 to $50K. It is not an extremely large cost but is excessive when compared to our revenue base.
08/17/2005 22:55:14 No, it is not unduly costly. We might have saved $5,000 to $10,000 last year, or < 0.01% of revenues. Investors still want printed annual reports, even after the annual meeting.
08/18/2005 08:03:31 This is not a unduly paper costs for printing/distribution is about $15K.
08/19/2005 02:56:12 PDF delivery and filing would be Awsome! Having done the EDGAR filings in house since EDGAR's inception, its a cumbersome, outdated and frustrating system. Simple PDF's and word processing documents are sufficient.
08/19/2005 11:44:44 It is extremely costly, especially considering the limited audience we have. Thousands of dollars are spent on printing and mailing the proxy and annual report, not to mention staff time and review by legal counsel. Electronic delivery would at least save on printing costs.
08/19/2005 13:49:01 The major portion of the costs associated with the preparation of proxy statements represent costs that would be incurred whether or not the proxy statement was printed or distributed electronically. Costs of this nature are preparation time and legal costs. Additionally, it would be inappropriate to limit the distribution of proxy statements as complete electronic delivery since there are still numerous investors who do not have the ability to receive electronic delivery.
08/19/2005 14:40:28 No comment.
08/19/2005 14:50:07 We could save approximately $20,000 by eliminating the need to print and distribute annual reports.
08/19/2005 17:03:28 Complete electronic delivery would allow these companies to save money on printing and paper, and be able to still reach the majority of their investors.
08/21/2005 03:34:34 Yes, it became very costly to circulate the proxy statement to all shareholders, and an electronic delivery system should be available.
08/22/2005 14:21:23 The real problem is the size of the notes. The requirements result in far too much information being put out that only a CA/CPA would understand anyway!
08/22/2005 15:20:23 Yes, paper is too expensive. We are now in the electronic era and we would be at least as effective doing this electronically.
08/22/2005 15:47:02 Absolutely. 50% could be saved. ADP is a monopoly, and electronic distribution might be able to reduce costs.
08/22/2005 15:47:34 No.
08/22/2005 17:54:28 Yes, these activities should move entirely to on-line filings. Eliminating paper filings would save us about 0.4% of revenue.
08/22/2005 17:56:59 Yes. Costs are equal to cost of Q and K reporting, and could well be streamlined.
08/22/2005 19:27:18 Annaul report costs can run around $30-$60k. I think they should be online and avaialbel upon requests. Most people will only read the presdents letter and scan the rest. It's outdated by the time it arrives! I am a CFO and I rarely read the annual report of the companies I invest in!
08/22/2005 20:10:17 The costs are substantial. Electronic delivery would be very acceptable and provide a more reliable avenue for response. Many do not mail or phone their proxy votes back. If there was a click to return response, I believe there would be a much higher per centage of response.
08/23/2005 00:42:38 somewhat burdensome. savings would be appx $10K.
08/23/2005 15:56:30 The cost is prohibitive - we would probably choose to print materials even if complete electronic delivery were allowed.
08/23/2005 16:06:08 I don't believe these cost to be overly burdensome. The costs tend to rise when companies turn their reports into a marketing piece. Having said that, I support electronic delivery.
08/23/2005 16:49:34 Yes - It would save our company over $20,000 annually
08/23/2005 18:10:00 Very expensive and outdated. PDF is adequate.
08/23/2005 21:11:03 The costs are significant. To the extent possible all of the regular reporting requirements should be done electronically. Continuing the dependence on paper is anachronistic
08/24/2005 10:14:02 Going to electronic medium would be VERY helpful. All the necessary information could be simply posted on the company website for shareholder download and voting.
08/24/2005 12:24:07 it is expensive and not extremely useful for the majority of shareholders. should be on an exception basis. we spend about $15k per year on this and lots of man hours.
08/24/2005 16:19:27 yes and unnecessary,. Most investors could care less about electing auditors or board nominees. Our costs are about $15000. Investors should be giving a choice of voting with management automatically on routine issues. I throw away the 50 annual reports I get and never waste my time voting. I guarantee I am the rule, not the exception.
08/24/2005 16:26:56 No.
08/24/2005 16:54:47 no
08/24/2005 20:16:09 To save time we are doing a 10K "wrap" for our annual report. It is costly to priny and mail; and most of our shareholders read the balance sheet, income statement, and shareholder equity sections only.
08/25/2005 15:23:41 Yes - the costs are unduly. In today's technological environment it would be more conducive to deliver to shareholders electronically the required annual mailings. It would be more efficient in both cost and time for the filer and the shareholder.
08/25/2005 17:02:43 No.
08/26/2005 12:41:42 Complete electronic delivery should be allowed. Notice that the documents are available on the internet should be adequate. The Company should continue to respond to requests for hard copies.
08/26/2005 13:07:22 No. Many of our sharehodlers do not have the means to retrieve electronic transmissions. The greater cost is preparation of the information itself.
08/26/2005 15:31:29 I'm in favor of complete electronic delivery.
08/26/2005 16:22:08 There is a lot of flexibility here.
08/27/2005 11:21:03 I don't know these costs. However, posting proxy statements on company websites with email notifications should be reasonable.
08/28/2005 23:37:43 All SEC reporting should now be electronic. I do not know a single investor who does have access to a PC, and prefer to use this method of communication. Bankign has eased into the electronic workd with the implementation of the Check 21 program. It is now time for Financial Reporting 21.
08/29/2005 10:21:15 Such printing and delivery is a significant expense for us, approximating up to $100,000 by the time printing, preparation time and delivery are totaled. In an electronic age where so many other things are being delivered electronically (to many end user´s preference), it would seem to be a logical way to further reduce unnecessary cost on all businesses and allow such funds to be reinvested in the core operations of the business. One comment relative to electronic delivery via e-mail is that current e-mail addresses can be a challenge to maintain administratively (given the fact that residential e-mail addresses seem to change very often); however, with a significant portion of the investment population having internet access, it would seem that posting such documents on the Company´s website (and the website being disclosed in the Company´s 10-K and 10-Q filings) for access rather than physical delivery would be a viable and administratively feasible alternative.
08/29/2005 10:21:25 Such printing and delivery is a significant expense for us, approximating up to $100,000 by the time printing, preparation time and delivery are totaled. In an electronic age where so many other things are being delivered electronically (to many end user´s preference), it would seem to be a logical way to further reduce unnecessary cost on all businesses and allow such funds to be reinvested in the core operations of the business. One comment relative to electronic delivery via e-mail is that current e-mail addresses can be a challenge to maintain administratively (given the fact that residential e-mail addresses seem to change very often); however, with a significant portion of the investment population having internet access, it would seem that posting such documents on the Company´s website (and the website being disclosed in the Company´s 10-K and 10-Q filings) for access rather than physical delivery would be a viable and administratively feasible alternative.
08/29/2005 11:21:29 No.
08/29/2005 14:18:47 I have no impression to share on this question.
08/29/2005 14:53:30 Yes. It is antiquated to insist on an obsolete means of communications, which does not result in the information being timely.
08/29/2005 15:31:21 The cost does not seem unbearable, but any time reports can be delivered electronically, a savings would occur.
08/29/2005 16:20:53 No
08/29/2005 17:09:27 Electronic delivery of these statements would not be well received by the maany of the local, smaller shareholders of this small company.
08/29/2005 17:12:26 all in all the costs are about $10,000 currently which doesn't sound like a lot, but would be a saving if we could deliver electronically instead.
08/29/2005 17:36:32 Absolutely too expensive and time consuming. Electronic delivery is definitely the way today. The click of a button compared to getting quotes for printing, cost of mailing, cost of polling brokers etc. I don't know the exact number for us at this moment but it is mre than we can afford.
08/29/2005 19:02:32 No problem.
08/29/2005 19:05:24 While the costs of preparing and distributing printed paper versions of the proxy and annual report are manageable, we are uncertain what, if any, benefit is provided. Although we have not performed any survey or questionnaire, our perception is that, with the exception of a few retail shareholders, shareholders no not desire a paper version of the proxy or annual report. We would support complete electronic delivery of documents. Companies could make a determination whether to continue to produce paper versions to provide on requested by retail shareholders who prefer a paper version.
08/29/2005 21:00:01 We provide limited numbers of hard copies and prefer to distribute electronic versions. We do provide paper versions for proxy statements - a change over to electronic would be very welcome and probably save ~$50k per year at a minimum.
08/29/2005 22:40:58 It would cut costs by at least 50% if full electronic delivery of documents was allowed.
08/30/2005 15:04:16 The costs are justifiable, given the need to communicate to investors. However, electronic delivery should be provided as an option to investors
08/30/2005 15:07:00 The cost is not unduly burdensome.
08/30/2005 17:08:46 No, the costs of distributing paper versions of proxy statements and annual reports to shareholders are not unduly costly for smaller companies. We would save about $15,000 annually if the SEC allowed all electronic delivery of documents. Although the costs of preparing paper documents are not prohibitive, given the widespread use and availability of the Internet, it seems that paper reporting will be shortly obsolete and redundant if it is not so already.
08/30/2005 18:26:14 N/A
08/30/2005 18:48:02 It is unduly costly for everyone and the SEC should get with the program, allowing for electronic delivery of everything to people who prefer it.
08/30/2005 21:07:56 Depending on the investor base and quantity required to publish - could be in the hundreds of thousands.
08/30/2005 21:39:41 Electronic distribution would save the Company up to approximately $50,000.
08/30/2005 23:57:28 Yes. about $15,000 - $20,000 per proxy.
08/31/2005 08:31:59 Yes, more disclosure results in more paper costs. $25,000 to $35,000 could be saved.
08/31/2005 10:19:14 For small companies, the cost of distributing paper versions of proxy statement and annual reports is generally $100,000 to 300,000 depending on the number of shareholders. The majority of this cost could be saved if electronic distribution were permitted.
08/31/2005 14:00:12 No. Total cost of proxy and annual is approximately $30,000.
08/31/2005 14:00:16 Costs incurred are design, printing, and distribution. Printing and mailing costs are directly related to the number of stockholders. In our case, we have a full in-house advertising department that does the design. The variable cost is in the annual report - color, etc. That can be managed effectively if desired. I don't see the costs as unmanagable or unrealistic for small companies.
08/31/2005 14:25:37 Yes. Our annual report to shareholders cost $23.70 each for year end 2004 and that did not cover the new SOX regulation.
08/31/2005 14:32:46 In our case, costs are not unduly high.
08/31/2005 15:19:27 Yes, that just makes sense. It would also be good for the environment.
08/31/2005 16:13:45 The costs of preparing and distributing printed paper versions of proxy statements and annual reports is costly be not unduly so. The electronic distribution of documents would be an improvement if the software used was improved form the current Edgar method. The current Edgar method is cumbersome and costly when assistance is used. The use of more user friendly software such as Word, Word Perfect etc. would greatly enhance the document delivery process.
08/31/2005 16:16:33 26. In today´s age, documents should generally be available in electronic form, especially for dissemination to the public and investors. Though the paperless society concept has not materialized, companies are able to save thousands of dollars by eliminating as much paper as possible. Our company would save approximately $160k per year by providing electronic copies of our financial statements to all investors. We suggest this service to our current stockholders, and some of them have already taken advantage of this service. Due to day traders and other short-term holders, many stockholders may not even own the stock by the time the reports are received via mail. Time is of the essence in today´s society, and many investors read online versions of our statements.
08/31/2005 17:16:33 No. But allowing the posting on the website would be good.
08/31/2005 18:22:30 We do not believe the costs are unduly burdensome. Most companies treat the annual report as a marketing tool and do not take a low cost approach.
08/31/2005 18:23:08 Yes, the cost is excessive for smaller companies. Assuming the smaller company does not include excessive design and marketing to the report, the majority of the cost is the printing and shipping. We estimated our print vs. electronic costs are 2.5 to 1.
08/31/2005 19:16:05 Electronic delivery of proxy materials is a noble goal, but I frankly wouldn´t know where to send ours. Also while the use of computers is widespread, it simply is not universal.
09/01/2005 11:40:19 I think electronic delivery would help all companies and investors from an efficiency standpoint.
09/01/2005 14:30:54 The cost of these mailings is clearly a burden for smaller companies. Because of the Edgar system, SEC reports are easily available on-line and can and should be distributed this way. We estimate that it costs our company over $20,000 in costs to do these mailings and we have very few shareholders.
09/04/2005 07:42:16 Yes. Our experience show that most investors use the soft version. Such costs can reach a few 10th thousands of USD which can be saved.