On September 19, AIMA submitted its response to the SEC's proposed rule entitled "Regulation E-Delivery," which would formally facilitate electronic delivery of required disclosures, reports and communications to investors and market participants as the default method of distribution (the "Proposal").

AIMA is supportive of the Commission's effort to modernize delivery of disclosures and reduce unnecessary paper-based burdens. Our response goes on to make the following arguments:

1. The obligation to send copies of historical documents should include targeted relief from the three-business day turnaround requirement;
2.  Limits should be set on the number of printed or historical documents that must be provided free of charge;
3.  The definition of "personal financial information" should be harmonized with Regulation S-P's definition of "sensitive customer information," or clarified where it is not intended to align;
4.  Delivery requirements should include targeted relief for institutional investors and accredited investors/qualified purchasers, governed by customer agreements rather than regulatory requirements;
5. Electronic access via investor portals should satisfy delivery requirements for certain routine documents, such as annual updates, rather than requiring affirmative delivery;
6. The statement of availability requirements should allow flexibility around directing investors to a general access point rather than mandating individualized document links;
7.  Transition periods should be shortened from the current six-month and one-month periods to reduce the burden of maintaining parallel delivery systems; and
8. The proposed rule should clarify whether delivery via physical media, such as USB thumb drives, is a permissible alternative to "paper delivery" under the rule.

Please reach out to Sarah Gaynor with any questions.