August 7, 2015
I oppose the proposed SEC Rule 30e-3. Shareholder reports should be available to investors in printed form and printed reports should be the default option unless an investor wishes to opt-in to electronic reports.
Some points to consider:
Paper is still the preferred method of transmission for investors. According to the 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 do online materials.
Proposed Rule 303-3 would impede access for many investors, especially the elderly, those with disabilities, and minority Americansall 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 (Pew Research Center, 2014). According to the Investment Company Fact Book, 34 percent of this population owns mutual funds.
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 (Two Sides, 2015).
With the depth of material in typical shareholder reports, reading a printed copy is the much preferred option. It is easier to take notes on a printed copy and the investor can stop at any point and pick up reading again later much easier. As stated above, many investors simply don't have internet access, including members of my own family.
Thank you for your consideration of this important matter.