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U.S. Securities and Exchange Commission

The following Letter Type C, or variations thereof, was submitted by individuals or entities.

Letter Type C:

Secretary Brent J. Fields
Securities and Exchange Commission
100F Street, NE
Washington, DC 20549-1090

Dear Sir:
I am firmly opposed to the proposed new regulation (new Rule 30e-3) which would eliminate the current default requirement for mutual funds to transmit important information to investors in paper form.

Paper is still the preferred method of transmission for investors.  Your own SEC study (Gale & Siegal 2012), stated 71% of Americans prefer to read annual reports in paper format rather than online versions.  Respondents in that study also asserted that printed materials yield higher content comprehension than online materials.  A more recent national survey (Two Sides, May 2015), indicated that 88% 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% of respondents prefer to read print on paper.

This proposed new regulation goes AGAINST the preference of the individual investors.   The current format of having investors "opt-in" for e-delivery is far superior than the proposed new Rule 30e-3.   Not only that, but, according to PEW Research (2014), your proposal would impede access for many investors, especially the elderly, those with disabilities, and minority Americans that are less likely to have regular internet access.    41% of Americans 65 or older do not use the internet, yet, according to the Investment Company Fact Book (2015, page 116), 34% of this population owns mutual funds.  How will they get investment information????

The facts given above make it very clear that New Rule 30e-3 is a bad idea and would harm millions of investors.   The SEC needs to ensure it will protect individual investors by supporting their wishes as to how investment information is communicated to them.   Please do not allow new Rule 30e-3 to pass.

Thank you,

 

http://www.sec.gov/comments/s7-08-15/s70815-62.htm


Modified: 08/03/2015