SIFMA and other financial associations urged the SEC to recognize electronic delivery ("e-delivery") as the primary method for the delivery of investor communications.
In a discussion paper, SIFMA and its Asset Management Group, the Financial Services Institute, the Investment Advisers Association, the Committee of Annuity Insurers, the Insured Retirement Institute, and the American Council of Life Insurers (collectively, "the Associations") proposed that the SEC allow firms to change their default delivery method from postal delivery to e-delivery. The Associations recommended e-delivery for:
- brokerage statements;
- transactional filings;
- investment adviser brochures;
- Regulation S-P privacy notices;
- Form CRS; and
- free credit balance notice requirements.
Under the Associations' recommended framework, after a one-year transition period, firms would begin using e-delivery to send required investor communications to existing clients with appropriate notice but without affirmative consent. New clients would be informed during enrollment that they will be enrolled in e-delivery automatically if they provide an e-delivery address, unless they elect otherwise. The Associations emphasized that in all circumstances investors could opt to receive paper communications.
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