August 11, 2015
Dear Secretary Fields:
I am writing to express serious concerns with the proposed Rule 30e-3, which would make electronic communication of earnings statements and other important mutual fund information the default for consumers.
Simply stated, this rulemaking as unnecessary. Mutual fund customers already have the freedom to choose electronic delivery of this important information if they wish. My concern is that this rule, if adopted in its current form, is essentially slamming customers that are now receiving this information in paper form into a delivery vehicle that many do not prefer, understand or even have access. In fact, according to the Security and Exchange Commissions own study conducted in 2012, over 70 percent of American investors said they prefer to read annual reports in paper format rather than online versions. For this segment of the population, Rule 30e-3 represents a significant cost shift from the mutual fund manager to the consumer as those that prefer reading this information in paper format would be forced to print the material at their own expense.
Finally, the fact is that a surprising number of American households—over 25 percent--do not have access to the Internet. At a time when U.S. policymakers are emphasizing the importance for everyone to save and invest for the future, it seems odd that the SEC would be proposing a rule that makes it more difficult and costly for large segments of the population to access important information about how their hard earned investments are faring.
In short, I view this rulemaking as a solution in search of a problem and respectfully request that Rule 30e-3 be withdrawn.