Sep. 14, 2026
Dear Commissioners: I am writing to oppose allowing electronic delivery of required investor information by default without the investor's clear agreement. I founded Holon Insights Consulting and have decades of experience developing print, mail, and digital communication solutions. I use digital services extensively and support innovation. My concern is how this proposal affects the whole system, including the people receiving the information. Lower delivery costs for an institution do not automatically mean a better system for investors. We must also consider the costs, responsibilities, and risks transferred to consumers. I appreciate that the proposal includes free paper options and notices before changing existing paper recipients to electronic delivery. Those protections matter. However, asking people to choose their delivery method provides stronger protection than requiring them to act to keep the service they already receive. Using an app to check an account balance does not mean someone wants every important financial document delivered electronically. Providing an email address does not establish that preference either. A person's failure to respond to a notice should not be treated as a clear choice. We must also consider what happens when digital access fails. An investor may lose electricity, internet service, access to a device, or the ability to enter an institution's online portal. The entire internet does not have to go down for that person to lose access to important records. A paper document already in the investor's possession provides a dated record that can be read without electricity, passwords, or a network connection. It cannot restore access to money or show transactions made after it was issued. It does, however, preserve information outside the institution's portal. Paper can also be lost or damaged. Keeping records in more than one form helps protect against different kinds of failure. We should design communication systems to serve people during disruptions as well as during normal conditions. Digital delivery also carries costs for the recipient. It requires a suitable device and internet or mobile data access. Even a free email account depends on that access. Receiving and reading a mailed document requires no internet subscription, electronic device, ink, or printer. Suggesting that consumers can print documents at home assumes they own a working printer, have supplies, and can find and print the information. Others may need to travel or pay for printing services. That is not an equal substitute for receiving a paper document from the institution. Many people already pay for devices and internet service. The full cost should not be assigned to this proposal. But the Commission should not assume that finding, saving, printing, and managing financial records creates no additional expense or work. I strongly support the proposal's requirement that paper copies and ongoing paper delivery be provided free of charge. That protection should be explicit and enforceable. Investors should not face a per-statement fee, a higher account maintenance fee, or another surcharge because they choose paper for required information. Fees can pressure people into electronic delivery even when paper better meets their needs. Providing required investor information should be treated as part of serving the account, rather than a separate source of revenue. A paper option is only a meaningful choice if investors can select it without a financial penalty. Security is another important concern. Investors must decide whether emails, texts, websites, and apps are genuine. The FBI has warned that criminals use generative AI to create convincing messages and fraudulent websites that imitate legitimate organizations. The Commission should consider the burden placed on consumers who must recognize these scams. FBI warning on AI-enabled financial fraud: https://www.ic3.gov/PSA/2024/PSA241203 Physical mail operates within an established postal system. The U.S. Postal Inspection Service is a dedicated federal law enforcement agency that investigates mail fraud. For properly documented commercial mailings, Intelligent Mail barcodes, Mailer IDs, and mailing records can help trace the businesses involved in preparing and submitting the mail. These tools provide a foundation for accountability. U.S. Postal Inspection Service: https://www.uspis.gov/tips-prevention/mail-fraud USPS Mailer ID guidance: https://postalpro.usps.com/mailing/mailer-id Receiving something in the mail does not guarantee that it is genuine. A barcode does not prove that its contents are true, and tracing a mailing may require additional records. Digital systems can also provide strong security. Still, preserving a physical channel gives investors another way to receive and keep information without relying on an unexpected electronic message or login request. As AI makes impersonation more convincing, I believe this independent physical channel becomes more valuable. The Commission should examine how investors can verify who sent a communication and get help when something appears wrong. Free paper on request is an important protection. But people must first notice the change, understand their options, and complete the steps needed to keep paper delivery. The ability to request paper after a problem occurs does not replace having a record available when the problem begins. I respectfully ask the Commission to: • Require a clear choice before changing delivery methods. Preserve existing paper delivery until the investor agrees to switch. • Guarantee paper delivery without added fees. Prohibit direct statement charges and indirect fees tied to choosing paper for required investor information. • Make paper requests simple. Allow requests by telephone or mail without requiring internet access. • Require plans for access failures. Establish clear ways to obtain records when electronic delivery fails or a portal is unavailable. • Consider the full burden on consumers. Include the time and expense of finding, saving, printing, and troubleshooting documents. • Evaluate fraud and verification risks. Examine how investors can confirm the sender, report suspicious messages, and use another channel when digital access may be compromised. • Measure useful access. Consider whether investors can find, keep, understand, and act on information, beyond whether it was sent. Electronic delivery can be fast, convenient, and accessible. Investors who want it should be able to choose it. Those benefits should be offered alongside meaningful choice, free paper access, and clear responsibility for security. I urge the Commission to revise the proposal to preserve affirmative consent and retain strong, enforceable protections for free paper delivery. Progress should be measured by how well the system protects and serves investors-including when technology fails or a communication cannot be trusted. Sincerely, Lori Joyner-Swetlin Founder, Holon Insights Consulting lori@holoninsights.com