Subject: File No. S7-08-15

August 5, 2015

Paper is still the preferred method of transmission for investors. According to SEC?s own study conducted by Siegel + Gale in 2012, 71 percent of American investors said they prefer to read annual reports in paper format rather than online versions and a large number of respondents also asserted that printed materials yield higher content comprehension than online materials.1

Rule 30e-3 would impede access for many investors, especially the elderly, those with disabilities, and minority Americans ? all demographics that are less likely to have regular Internet access. For example, 41 percent of Americans over 65 years of age do not use the Internet, yet, according to the Investment Company Fact Book, 34 percent of this population owns mutual funds.2, 3

Paper is a superior distribution method for important information. In a recent national survey, 88 percent of respondents said that they understand and can retain or use information better when they read print on paper, and when given a choice, 81 percent of respondents prefer to read print on paper.

I do not agree that investors are ready for this new rule. It is not fair to the investor unless there is free internet services provided into homes. Then the default could be electronic instead of paper reports. Paper reports should remain the default with the choice to option electronic. There still should be the choice to receive both.

 

Mark D. Eisenhart
Assistant Papermill Superintendent Papermaking
Glatfelter
www.glatfelter.com