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09/09/2026

Paper Choice at a Crossroads: Proposed E-Delivery Rules Deserve Our Attention

Source: Two Sides North America, September 2026

The Future of Paper Choice: An Important Conversation for Our Industry

For years, consumers receiving important financial documents have generally received paper unless they affirmatively elected electronic delivery. The Securities and Exchange Commission is now considering a significant change to that approach.

The SEC's proposed Regulation E-Delivery would establish conditions allowing covered organizations to deliver certain required information electronically without first obtaining affirmative consent from the recipient. Individuals would retain the ability to opt out and request paper copies. The proposal covers a broad range of financial communications, including shareholder reports, prospectuses, proxy materials, trade confirmations, and certain investment adviser disclosures.

The SEC describes the proposal as an effort to modernize communications, improve accessibility, and reduce paper, printing, and postage costs.

Two Sides North America and other paper industry organizations are raising concerns about what changing the default could mean for consumer choice and access to printed communications. Two Sides notes that consumers who prefer electronic delivery can already choose it, while the proposed approach would instead require people who prefer paper to take action to retain it.

The issue may be particularly important for consumers who are less comfortable accessing sensitive information online or who have concerns about fraud and phishing. Two Sides is encouraging its members and the broader industry to raise awareness of the proposal and participate in the public comment process.

Make Your Voice Heard by September 21

The SEC's official public comment period for Regulation E-Delivery remains open through September 21, 2026.

The Paper Choice Coalition has created a resource where individuals can learn more and submit comments:

SEC Public Comments: Protect Paper Choice

For those who want to review the proposal directly, the SEC also provides the proposed rule, supporting materials, and its official public comment process:

Review the SEC Regulation E-Delivery Proposal

This is an important issue for our industry and the customers we serve. We encourage GMA members to educate themselves on the proposal, share the information with employees and customers, and participate in the public comment process if they choose.

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