ICI presses SEC on default e-delivery for fund documents

The Investment Company Institute is urging the Securities and Exchange Commission to update its rules and allow funds to deliver regulatory documents to investors electronically by default – a move the group says could save billions of dollars and better reflect how Americans manage their finances today.

In a letter to SEC Chair Paul Atkins, ICI cited new estimates showing that a shift to e-delivery could save funds and their shareholders between $589 million and $797 million annually, with cumulative savings of $3 billion to $4 billion over five years. The group’s analysis, based on industry data and survey results, suggests that the majority of investors already prefer electronic delivery and are comfortable engaging online for financial transactions.

“ICI’s data finds that – even using conservative estimates – American middle-class investors would save several billion dollars by switching to default e-delivery,” Eric Pan, president and CEO of ICI, said in a statement Wednesday. “Not only is e-delivery cost efficient, investors want it. Our survey shows a vast majority of Americans support an e-delivery default.”

According to the ICI survey – which was conducted in July, with the findings being released in September – 88% of fund investors agree that making e-delivery the default is a good idea, as long as people can still request paper at no cost. Support remains strong even among older investors, with 87% of those aged 65 or older in favor. The survey also revealed that about 70% of fund investors prefer e-delivery regardless of document type, and 84% already receive at least some of their financial documents electronically.

ICI's open letter argues that the current paper-based default is outdated, pointing to the near-universal internet access among US adults and the widespread use of online investing and banking. It maintains that e-delivery is not only more efficient but also offers enhanced investor protections, such as faster and more secure communications compared to paper mail, which can be lost or stolen.

“Electronic delivery of documents provides many benefits to funds and their shareholders,” ICI argued in its letter. “Moving to a default e-delivery standard would allow funds to meet investors’ preferences without burdening investors or sacrificing important investor protections.”

ICI’s recommendations to the SEC include ensuring that electronic delivery methods remain flexible and technology-neutral, allowing investors to opt for paper delivery at any time, and holding funds delivering electronic documents to the same standards as those delivering paper.

The group also called for reforms to New York Stock Exchange processing fees, which it says could unlock even greater savings for investors.

The push for regulatory change comes as Congress considers the Improving Disclosure for Investors Act of 2025 – a bill mirroring one advanced in the House last year – which would direct the SEC to permit e-delivery as the default method for regulatory documents.

ICI expressed support for the legislation, but said the SEC should act regardless of whether Congress moves forward.

The group’s analysis suggests that a sizeable share of investors who still receive paper documents could benefit from an e-delivery default, with nearly four in ten citing reasons such as the time required to sign up or issues with current processes. ICI emphasized that any new framework should preserve the ability for investors to receive paper documents if they choose, but argued that the default should reflect the preferences of the majority.

“The time is right for default e-delivery, irrespective of Congressional action,” the ICI letter read in part. “We are confident that the Commission will conclude that default e-delivery is common sense, cost-effective, and pro-investor policy worth enacting.”