August 7, 2015
I would respectfully ask that you not place an undue burden on investors by shifting the default delivery method for critical shareholder reports from paper to e-delivery. While I'm sure this is motivated by nothing more than a cost savings attempt, I would ask that the SEC act in a more caring and professional manner by looking to save those dollars elsewhere. The following bullet points are real and the people we should desire to help the most will absolutely be harmed by this legislation:
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).
I CAN ASSURE YOU THAT THERE WILL BE MORE LEGAL ISSUES AS A RESULT OF WHAT YOU'RE PROPOSING TO DO THAN YOU ALL HAVE CONSIDERED. SLOW DOWN, REVIEW THIS APPROPRIATELY AND INSTEAD FIND YOUR SAVINGS ELSEWHERE.