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SEC Proposing to go Paperless...

Posted Tuesday, August 4, 2015 by Jules VanSant.

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As you may know, the Securities and Exchange Commission (SEC) has published a proposed rule ( Rule 30e-3) that would eliminate the current requirement for important mutual fund information to be transmitted to investors in paper form. Under the SEC’s current rules governing mutual fund disclosure, investors already have the ability to opt-in to electronic delivery, yet only a small minority has chosen to do so.

By permitting funds to satisfy shareholder report requirements by making shareholder reports and quarterly portfolio holdings available only online, Rule 30e-3 would shift the burden on investors. Under the provisions of the proposed rule, investors would simply be sent a letter announcing the switch to digital delivery. A lack of response would be deemed “implied consent” to the switch. This has major implications to companies that print financial services material and to the ongoing efforts of the Federal government to “go paperless.”

Printing Industries of America and its allies in the Consumers for Paper Options are urging the SEC to instead maintain the spirit of the 1933 Securities Act to provide investors with all the reasonable information they need to make informed investment decisions and ensure shareholder reports remain accessible to all Americans. In other words, rescind or revise the proposed rule. Comments have been filed to this end (copy available here) and the industry is urging Congress to weigh in with the SEC to support our case. But this rule is moving fast (comments are due on August 11) and all hands are needed on deck to make the industry’s case.

Here’s how you can help our industry and your company:

1) a.) Register your opposition via public comments here by August 11; b) contact your Senators/Representative to register concern. A mass action alert is forthcoming this week from PIA national, but speed is of the essence and I urge you to move quickly.

2) Call into a conference call this week hosted by Consumers for Paper Options to learn more about the industry’s battle on the SEC issue. The call will be held at 3:00 p.m. Eastern on Thursday, August 6th. The call-in number is: (712) 775-7031; the passcode is: 975-183-691#. You can also learn more in advance of the call by visiting