SEC's E-Delivery Modernization Will Save American Investors Billions of Dollars

SEC Should Finalize Rule to Bring Shareholder Disclosure into the 21^st Century

WASHINGTON, Sept. 22, 2026 /PRNewswire/ -- The Investment Company Institute (ICI) submitted a comment letter supporting the Securities and Exchange Commission's (SEC) proposal to make electronic delivery (e-delivery) of information under the federal securities laws the default option for investors. The move is a much-needed update to better reflect how investors access information today and will save fund shareholders billions of dollars. ICI President and CEO Eric J. Pan commented that:

"The vast majority of American investors today access financial information online. The SEC's proposal is a great step towards bringing outdated paper delivery requirements into line with investors' preferences, and we thank Chairman Atkins and the SEC staff for this important proposal. We also recommend some additional changes to build on this strong foundation and make a final 'Regulation E-Delivery' a durable, technology-neutral framework that can serve fund shareholders for decades.

"ICI's research shows funds and fund shareholders could save billions of dollars by shifting to e-delivery, which is good for the millions of Americans investing for a secure financial future. Importantly, investors will always have the choice to receive information through the mail. We encourage the SEC to finalize this rule swiftly."

In its letter, ICI strongly supports the core elements of the proposal, including:

• Making electronic delivery the default method for delivering fund disclosures.
• Preserving investors' ability to choose paper delivery, for free, at any time.
• Requiring reasonable safeguards for personal financial information.
• Requiring firms to take reasonable steps to address failed electronic deliveries.

ICI also suggests several targeted improvements to ensure the benefits of electronic delivery reach all investors and ensure the rule remains operationally straightforward.

ICI encourages the SEC to:

• Permit "access equals delivery," where certain standard fund documents, such as shareholder reports, are made available online.
• Allow a "paper notice and access" option for investors who do not have electronic contact information on file.
• Relax hyperlink requirements, since many firms use secure login portals for account-specific information.
• Preserve the existing "notice and access" framework for the delivery of proxy materials.

The letter includes a renewed call to reform the current processing fee structure, which unreasonably inflates information delivery costs for funds. Adoption of e-delivery, along with processing fee reform, would allow fund shareholders to realize the full cost-saving benefits of e-delivery.

ICI's research shows funds and their shareholders could save $3 billion to $4 billion over five years from transitioning to e-delivery. According to ICI's Americans' Views on E-Delivery on Financial Documents survey, 88% of fund investors agreed that "as long as people can still request paper at no cost, it's a good idea to make e-delivery the default."

The letter notes that e-delivery will improve the investor experience, reduce operational and mailing costs, minimize paper waste, and better reflect how investors already interact with financial information. Click here to read the full letter.

Contact: [email protected] 

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SOURCE Investment Company Institute