July 18, 2022

Honorable Gary Gensler
Chair
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549

Re: E-Delivery Investor Survey Results

Dear Chair Gensler,

The Securities Industry and Financial Markets Association (“SIFMA”)1 and its members believe the time has come for the Securities and Exchange Commission (“SEC” or “Commission”) to amend its rules to make e delivery the default mechanism for transmission of investor communications and disclosures. Investors increasingly access some or all such material electronically, notwithstanding the required default to paper delivery. By establishing e-delivery as the default mechanism for investors with active email addresses, clients would avoid cumbersome processes to convert to e-delivery. We believe this method is more secure, user friendly, and environmentally sound. Furthermore, with the pending acceleration of the securities settlement cycle to T+1, e-delivery will be necessary for the delivery of confirmations for broker-dealers to be compliant with the new rules.

In your 2021 United States Senate confirmation hearing, in response to a question from Senator Tillis regarding electronic delivery2, you appropriately noted your prior leadership in promoting technology as a means of delivery with respect to federal payments to individuals and the adoption and implementation of the e-Signature act, and further committed to make e-delivery a priority. We very much welcome this commitment as it is consistent with your prior work and also with the Commission’s past leadership in modernizing disclosure rules to enable the use of new communications technologies.

 

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.

2 https://www.congress.gov/event/117th-congress/senate-event/LC67970/text