August 7, 2015
Mr. Brent J. Fields
Securities and Exchange Commission Friday, August 07, 2015
100 F Street, NE
Washington, DC 20549-1090
RE: Investment Company Reporting Modernization: Release Nos. 33-9776; 34-75002; IC-31610; File No. S7-08-17
Dear Secretary Fields,
Good Day and I respectfully ask you to reject new Rule 30e-3. E-Delivery of shareholder reports would create a very difficult and time consuming way of reading financial information. It is very cumbersome to read and refer to this type of information on a computer screen due to the complexity of the reports. With paper reports, it is much easier to study and comprehend the technical nature of the reports and not have the discomfort of staring at a screen with one page at a time.
With the paper reports, you are able to analyze the financial reports with much more clarity and understanding since you can turn the paper pages with a lot more ease than flipping around on a computer screen which is very distracting. With the paper reports, you can make notes in the margins. You can easily refer back to charts along with financial tables. I have included some various thoughts which help make my point.
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.
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.
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.
Thank you in advance for your consideration and again ask you to reject new Rule 30e-3.
Sincerely yours,
John S. Swift