August 4, 2015
I am commenting in opposition to the Securities and Exchange Commissions proposed Rule 30e-3, which would eliminate the current default requirement for mutual funds to transmit information to investors in paper form. I oppose this proposal on the grounds that it shifts the burden to investors by requiring them to opt-in to paper delivery of critical fund information rather than having the option to opt-in to electronic delivery. Shareholder reports are important tools for me as an investor, and implementing this change will potentially harm millions of my fellow investors the majority of whom have already expressed a preference for paper-based investment reports.
I believe that paper communication should remain the default option for this information because:
1. The majority of investors and myself, prefer to receive shareholder reports in paper format.
2. Significant portions of the population lack access to electronic services (my mother for example). Postal Mail delivery provides the broadest access to all recipients and should be the default option.
3. Paper communication has significant benefits over electronic communication for content such as shareholder reports.
In permitting funds to satisfy shareholder report requirements by making this information available on a website, Rule 30e-3 would make it more difficult for many investors to access the reports they need to make informed investment decisions. Rather than an automatic conversion of the default to electronic distribution, the SEC could provide guidelines for investment fund companies to prominently place information informing investors on electronic delivery options, particularly on generic proxy statements and other material that does not contain investor-specific information.
I respectfully ask that the SEC reconsider and formally withdraw Rule 30e-3.
Thank you for your consideration.