August 11, 2015
I am commenting today in opposition to Proposed Rule 30e-3 on several grounds.
Shifting the default method of various notifications to investors/potential investors to e-delivery is unwise and unhelpful, not only for these investors and the economy, but for the environment as well.
E-delivery is currently not the preferred method of communication for the majority of investors:
SEC surveys indicate that most investors prefer receiving important information through printed material; it is more clear, easier to understand, is retained better, thus helps to avoid confusion.
E-delivery places an undue burden on the elderly, minority investors and disabled investors. Pew Research surveys show that a disproportionate number of the elderly, disabled and minority investors have ready access to the internet.
E-delivery is detrimental to the environment. E-media account for nearly 15 percent of CO2 emissions, and exceed those of the paper industry by more than 2.5 times with little recapture, while managed U.S. forests absorb more than 100 percent of the CO2 released in papermaking.
There are many reasons why Rule 30e-3 is unwise, I have offered 3 of the most obvious. I ask that these be given full consideration.
Wes Westmoreland