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Summary

​In her December 15, 2020 letter to the Securities and Exchange Commission (SEC), Barbara Roper, representing the Consumer Federation of America, addresses the SEC’s proposal to modernize mutual fund disclosures. While expressing general support for creating tailored shareholder reports that emphasize key information for retail investors, Roper opposes industry suggestions to shift the default delivery method of disclosures from paper to electronic formats for investors who have provided an email address or smartphone number.​

Roper argues that simply changing the delivery default to electronic formats without reimagining the disclosures themselves would not fully harness the benefits of digital technology. She emphasizes the need for a comprehensive analysis to ensure that any transition to electronic delivery prioritizes investor interests and engagement, rather than merely serving industry convenience. Roper recommends that the SEC postpone adopting the industry’s proposed digital default until it can be evaluated within a broader disclosure modernization initiative that is data-driven and considers investor preferences and effective engagement strategies.

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