As the June 30 compliance date for Regulation Best Interest and Form CRS approaches, this Bloomberg Law article examines the SEC's current position regarding electronic delivery, where electronic delivery is permitted only if the customer affirmatively consents. Through statistics and a look-back in the history of electronic delivery approaches, the article makes a balanced argument for the benefits for default electronic delivery, with the option of paper delivery for investors who prefer paper delivery.
As a general matter the SEC permits electronic delivery of disclosure, including the relationship summary, only if the customer affirmatively consents. Any customer who does not request electronic delivery will receive disclosure in paper form, typically through the postal service. Paper delivery is the default method of delivery.....The question is whether paper delivery should be the SEC’s default position.