IRI VISION: TWO DECADES IN THE MAKING: A WIN FOR E-DELIVERY AND THE INVESTORS WE SERVE

Emily Micale
Director, Federal Regulatory Affairs
Insured Retirement Institute

Nearly two decades after IRI first pushed for it, electronic delivery is on track to become the default way investors get the information they’re entitled to under federal securities law.

In comments filed with the U.S. Securities and Exchange Commission (SEC), IRI voiced strong support for the agency’s proposed Regulation E-Delivery. It’s a win for IRI, for the industry we represent, and most of all for the investors who stand to benefit.

The proposed rule shares the core goals of IRI’s Digital First for Annuities initiative and our Federal Retirement Security Blueprint. And it’s grounded in something simple: most investors already prefer electronic delivery. E-delivery is more accessible, less expensive, and faster than paper, and it lets investors find, save, and retrieve their information whenever they need it, instead of waiting on the mail.

The proposal also preserves what IRI has always insisted on: the right to request paper, at any time, for anyone who wants it.

IRI’s comments back the rule and offer targeted refinements to help it work across the insurers, asset managers, broker-dealers, and distributors that serve investors every day. Chief among them: a clear path for legacy contracts.

Many annuities were sold long before anyone collected email addresses, and those investors shouldn’t be stuck on paper by default. IRI urged the SEC to let firms bring them on board through reasonable outreach, on a realistic timeline.

We also asked the SEC to honor the e-delivery choices investors have already made, let firms securely rely on the email addresses investors have already provided to affiliated firms and trusted partners, and offer an optional, shorter path to e-delivery.

We look forward to working with the SEC as it finalizes a rule that gives the millions of Americans saving for and living in retirement in the modern, digital-first experience they deserve.

Contact: Dan Zielinski