Data to Support Modernizing the Delivery Frameworks (SIFMA and SIFMA AMG)

Summary

SIFMA and SIFMA AMG submitted data to support SIFMA's proposal submitted to the Securities and Exchange Commission (SEC) on September 15, 2025 requesting that the Commission take necessary steps to modernize the framework for the electronic delivery of required communications and disclosures by market participants to investors, customers, and clients.

Excerpt

The Securities Industry and Financial Markets Association ¹ and its Asset Management Group ² (collectively, "SIFMA") are submitting data to support SIFMA's proposal submitted to the Securities and Exchange Commission ("SEC" or "Commission") on September 15, 2025 requesting that the Commission take necessary steps to modernize the framework for the electronic delivery of required communications and disclosures by market participants to investors, customers, and clients (collectively, "customers"). ³ To further support the proposal, SIFMA requested data from members on costs of delivering investor documents and potential cost savings if the Commission were to permit firms to treat electronic delivery as the default delivery method for required customer communications. The survey respondents included large and medium-sized broker-dealers, investment advisers, and dual-registrants with retail clients. SIFMA also conducted a separate survey for institutional businesses including broker-dealers and asset managers.

1. SIFMA members spend hundreds of billions of dollars annually to deliver documents to retail investors via postal delivery.

SIFMA's survey shows that firms are sending an average of 14 documents per retail account per year totaling billions of documents sent to retail investors. ⁴ The SIFMA survey showed that respondents spent on average $62 million per year on delivering documents to retail investors. Some large firms reported spending more than $130 million annually. Of these costs, over 95% were attributed to postal delivery - an average of about $60 million annually across all respondents, and as much as $144 million annually for large firms.

The cost of delivering paper documents by mail was reported to be an average of $1.45 per document. The cost of delivering electronic documents was less than 20 cents per document, and perhaps even less as some firms report that they have negotiated a flat fee for delivering electronic documents for customers who have opted in.

These results are further bolstered by the Commission's own filing to the Office of Management and Budget on the costs of delivering trade confirmations under Rule 10b-10. ⁵ The Commission found that the industry pays over $20 billion annually to deliver paper confirmations to investors which accounts for 80% of the $25 billion total cost of delivering both paper and electronic confirmations.