August 3, 2015
Dear Secretary Brent J. Fields:
I am writing to comment on proposed new regulation Rule 30e-3 and ask that it not be implemented. I, like most Americans, have a strong preference to receive, read, and retain my annual reports and other critical shareholder reports and documents in hard-copy via mail than in electronic form. I ask that this proposal be rejected and that electronic transmission remain the opt-in choice while leaving paper as the default method of distribution. Thank you for considering my input.
In addition, here are several reasons why I would request that this rule not be implemented:
1. Shift the burden to 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
2. Could potentially confuse million so investors who suddenly stop seeing important fund performance material from investment firms
3. Paper is still the preferred method of transmission for investors. According to the SEC’s own study conducted by Siegel and Gale in 2012, 71% of American investors said they prefer to reach their annual reports in paper format rather than online versions and a large number of respondents also asserted that p;ringed materials yield higher content comprehension than online materials. (1)
4. Rule 30e-3 would impede access for many investors, especially the elderly like my parents, those with disabilities like my son and minority Americans - all demographics that are less likely to have regular internet access. For example, 41% of Americans over 65 years of age do not use the internet, yet, according to the Investment Company Fact Boo, 34% of this population owns mutual funds. (2) (3)
5. Paper is a superior distribution method for important information. In a recent national survey, 88% of respondents said that they understand and can retain or use information better when they read print on paper and when given choice, 81% of respondents prefer to read print on paper (4)
(1) "Investor testing of Selected Mutual Fund Annual Reports (Revised),” Siegel and Gale, February 9, 201
(2) Pew Research Center, Older Adults and Technology Use, http://www.pewinternet.org/2014/04/03/older-adults-and-technology-use
(3) ICI Investment Company Fact Book p.116
(4) “Reading from Paper or Reading from Screens. What do Consumers Prefer?” Two Sides, May 2015
Bill Prettyman
President/CEO
Wise, Alpharetta GA