IRI SAYS SEC E-DELIVERY RULE ALIGNS WITH DIGITAL-FIRST GOALS

Proposed Regulation Supports Investors’ Preferred Choice of Information Sharing

WASHINGTON, D.C. – A proposed Securities and Exchange Commission (SEC) regulation would permit electronic delivery as the default method for sharing required regulatory information with consumers under federal securities laws.

The Insured Retirement Institute (IRI) strongly supports the proposed rule.

“Making e-delivery the default is a modernization that IRI has long sought, and it aligns with the goals of IRI’s Digital First for Annuities initiative and IRI’s Federal Retirement Security Blueprint,” wrote Emily Micale, Director, Federal Regulatory Affairs, IRI, in comments filed today. “IRI commends the Commission for independently advancing this reform through rulemaking and for grounding the proposal in documented investor preferences.”

Modernizing decades-old delivery requirements is a long-sought IRI priority. The trade association says that electronic delivery provides a more accessible, cost-effective, and faster way to convey and receive information than paper delivery.

Electronic delivery also creates opportunities for the industry to provide dynamic, real-time information rather than static data, making it easier for consumers to find, save, and retrieve information at the level of detail they prefer.

“The proposal aligns default delivery with the way most investors now prefer to receive information, while preserving the consumer choice that IRI has consistently advocated, in particular the durable right to request paper at any time,” Micale wrote.

IRI offered several recommendations to the proposed rule to make implementation workable and ensure maximum flexibility to continue e-delivery for customers already using that option.

IRI recommends that the new rule include provisions to bring legacy and in-force contracts with no electronic address on file into e-delivery, with adequate transition time, rather than defaulting those contracts to paper indefinitely.

IRI also seeks confirmation that the proposed rule’s exclusion of recipients already receiving e-delivery for all covered information from the transition process extends to existing valid electronic-delivery elections.

Additionally, IRI recommends that the SEC-proposed rule harmonize with the Department of Labor and Employee Retirement Income Security Act (ERISA) electronic-delivery safe harbor, FINRA rules, and state insurance requirements, so one compliant workflow can serve overlapping obligations in the same customer relationship.

“IRI appreciates the Commission’s leadership in advancing this modernization,” Micale wrote. “The recommendations are offered to make the rule workable across the insurer, asset manager, broker-dealer, distributor, and vendor relationships of the insured retirement industry, while preserving the consumer choice that IRI has consistently advocated.”

# # #

Contact: Dan Zielinski