June 12, 2015
It is my understanding that the Proposed Rule for Investment Company Reporting Modernization would eliminate the current default requirement for mutual funds to transmit important information to investors in paper form. Specifically, it would:
Permit funds to satisfy shareholder report requirements by making shareholder reports and quarterly portfolio holdings available only online. Shift the burden on investors by requiring them to opt-in to paper delivery of important fund information as opposed to the current option of opting-in to electronic delivery. Confuse potentially millions of investors who suddenly stop seeing important fund performance material from investment firms.
I am writing to relay important information to you about print and its importance. Below is an excerpt from a study completed that emphasizes the importance of print.
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).
If this rule passes then many investors over the age of 65 will not get their statements. More thought needs to be made about the passage of this rule. Many consumers today only listen to what the media is saying and do not take into consideration how vital print is to the world. Not only does Print save our environment by being recyclable but it provides an alternate crops for farmers who otherwise may sell there land for development. These trees help keep our environment clean through the use of carbon dioxide and the production or oxygen. Consider the computer and a piece of paper. Which of these when put in the rain is more environmentally friendly? Which of these does not emit toxic chemicals? I am requesting that the Proposed Rule 303-3 not be passed.
Thank you for your time and your consideration of these facts and ideas.
Have a blessed day!
Lydia J. Morgan
CEO, Morgan Printers, Inc.