Trade Associations
Here's a look at documents from national and international trade associations
Featured Stories
National Sorghum Producers Issues Letter to President Trump on U.S. Sorghum Producers Push for Guaranteed Market Access in Upcoming China Trade Talks
LUBBOCK, Texas, Sept. 23 (TNSletter) -- The National Sorghum Producers issued the following letter to President Trump on the U.S. sorghum producers push for guaranteed market access in upcoming China trade talks:
* * *
Here is the text of the letter:
September 18, 2026
President Donald J. Trump
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Dear President Trump:
As American sorghum farmers move through the 2026 harvest season, thank you for your determination to expand and diversify export markets for U.S. agriculture. On behalf of National Sorghum Producers, I write ... Show Full Article LUBBOCK, Texas, Sept. 23 (TNSletter) -- The National Sorghum Producers issued the following letter to President Trump on the U.S. sorghum producers push for guaranteed market access in upcoming China trade talks: * * * Here is the text of the letter: September 18, 2026 President Donald J. Trump The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 Dear President Trump: As American sorghum farmers move through the 2026 harvest season, thank you for your determination to expand and diversify export markets for U.S. agriculture. On behalf of National Sorghum Producers, I writeto reaffirm our appreciation for the progress achieved during your October meeting with President Xi in Busan, South Korea, and for securing China's subsequent commitment in May to purchase at least $17 billion annually in U.S. agricultural products, in addition to its soybean commitments, for the next three years.
This commitment represents an important opportunity for U.S. sorghum farmers. Ahead of your upcoming meeting with President Xi in Washington, D.C., we ask that you build on that progress by ensuring sorghum receives a meaningful share of China's agricultural purchases and by establishing a durable, long-term trading relationship that provides greater stability for American producers.
For U.S. sorghum producers, the importance of the Chinese market cannot be overstated. Historically, close to 80 percent of U.S. sorghum exports have moved to China. On average, those shipments have totaled approximately 5 million to 7 million metric tons and generated between $1 billion and $2 billion in annual value. China is not simply one important customer for our industry. Its purchasing decisions directly affect prices, local basis, storage availability and planting decisions across the Sorghum Belt.
The urgency is increasing. Through conversations with participants in the international sorghum trade, we have learned that, for the first time ever, significant volumes of Brazilian sorghum have moved to China. Brazil was granted access to the Chinese sorghum market in late 2024 and continues to expand its production and export infrastructure.
American sorghum farmers and industry partners have spent more than 15 years building a trusted commercial relationship with Chinese customers. Other agricultural sectors have demonstrated how quickly Brazil can capture market share when U.S. products face tariffs or uncertain access. If purchasing relationships and supply chains shift away from the United States, that market share may be extremely difficult to regain. Time is of the essence.
We respectfully ask that the following actions be prioritized during your meeting with President Xi.
First, we strongly support your administration's work to establish and operationalize a Board of Trade with China that would allow trade in non-sensitive goods to continue even as the United States and China address more sensitive trade issues. U.S. sorghum should be included among those non-sensitive goods.
Second, China continues to impose a 10 percent retaliatory duty on U.S. sorghum that does not apply to sorghum imported from Brazil or other competitors. This duty should be eliminated so U.S. sorghum is not placed at a competitive disadvantage and can be purchased freely by commercial firms, as well as Chinese state-owned enterprises.
Third, we ask that China's agricultural purchase commitments include a concrete and enforceable annual commitment to purchase a minimum of 5 million to 7 million metric tons of U.S. sorghum, or approximately $1.6 billion in value. This level of purchasing is consistent with established commercial trade between our countries and would provide reliable demand for American producers. True success will come when these commitments result in completed sales, vessels being loaded and grain moving from U.S. farms to customers in China.
Fourth, the one-year suspension of Section 301 port fees applied to Chinese vessels is set to expire during an important shipping period for U.S. agriculture. We are concerned that implementing these fees could increase transportation costs, disrupt shipping and ultimately pass additional expenses back to farmers. We ask that steps be taken to ensure Section 301 port fees do not disrupt or diminish U.S. sorghum exports.
In summary, U.S. sorghum farmers ask that you build on the progress of your previous meetings with President Xi by securing meaningful and enforceable purchase commitments, eliminating tariffs and trade barriers that place American farmers at a disadvantage to Brazil and other competitors, preventing shipping disruptions and prioritizing a long-term agreement that provides consistency and predictability.
National Sorghum Producers appreciates your continued attention to agriculture in U.S.-China trade negotiations. Restoring fair and reliable access to this critical market would support sorghum producers, strengthen rural communities and protect a valuable market that American farmers have spent years developing.
We look forward to positive outcomes from the upcoming summit.
Sincerely,
Amy France, Chair, National Sorghum Producers, Sorghum farmer, Scott City, Kansas
CC:
The Honorable Scott Bessent, secretary, United States Department of the Treasury
The Honorable Howard Lutnick, secretary, United States Department of Commerce
The Honorable Brooke Rollins, secretary, United States Department of Agriculture
The Honorable Jamieson Greer, United States trade representative
The Honorable Julie Callahan, chief agricultural negotiator
The Honorable Mike Crapo, chair, United States Senate Committee on Finance
The Honorable Ron Wyden, ranking member, United States Senate Committee on Finance
The Honorable John Boozman, chair, United States Senate Committee on Agriculture, Nutrition and Forestry
The Honorable Amy Klobuchar, ranking member, United States Senate Committee on Agriculture, Nutrition and Forestry
The Honorable Jason Smith, chair, United States House Committee on Ways and Means
The Honorable Richard Neal, ranking member, United States House Committee on Ways and Means
The Honorable Glenn Thompson, chair, United States House Committee on Agriculture
The Honorable Angie Craig, ranking member, United States House Committee on Agriculture
* * *
Original text here: https://sorghumgrowers.com/wp-content/uploads/2026/09/FINAL-NSP-A-Letter-to-President-Trump-US-China_Summit_9_18_26-1-1.pdf
News Release here: https://sorghumgrowers.com/2026/09/18/nsp-urges-progress-on-sorghum-trade-ahead-of-trump-xi-meeting/
[Category: Agriculture]
* * *
Here is the text of the letter:
September 18, 2026
President Donald J. Trump
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Dear President Trump:
As American sorghum farmers move through the 2026 harvest season, thank you for your determination to expand and diversify export markets for U.S. agriculture. On behalf of National Sorghum Producers, I write ... Show Full Article LUBBOCK, Texas, Sept. 23 (TNSletter) -- The National Sorghum Producers issued the following letter to President Trump on the U.S. sorghum producers push for guaranteed market access in upcoming China trade talks: * * * Here is the text of the letter: September 18, 2026 President Donald J. Trump The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 Dear President Trump: As American sorghum farmers move through the 2026 harvest season, thank you for your determination to expand and diversify export markets for U.S. agriculture. On behalf of National Sorghum Producers, I writeto reaffirm our appreciation for the progress achieved during your October meeting with President Xi in Busan, South Korea, and for securing China's subsequent commitment in May to purchase at least $17 billion annually in U.S. agricultural products, in addition to its soybean commitments, for the next three years.
This commitment represents an important opportunity for U.S. sorghum farmers. Ahead of your upcoming meeting with President Xi in Washington, D.C., we ask that you build on that progress by ensuring sorghum receives a meaningful share of China's agricultural purchases and by establishing a durable, long-term trading relationship that provides greater stability for American producers.
For U.S. sorghum producers, the importance of the Chinese market cannot be overstated. Historically, close to 80 percent of U.S. sorghum exports have moved to China. On average, those shipments have totaled approximately 5 million to 7 million metric tons and generated between $1 billion and $2 billion in annual value. China is not simply one important customer for our industry. Its purchasing decisions directly affect prices, local basis, storage availability and planting decisions across the Sorghum Belt.
The urgency is increasing. Through conversations with participants in the international sorghum trade, we have learned that, for the first time ever, significant volumes of Brazilian sorghum have moved to China. Brazil was granted access to the Chinese sorghum market in late 2024 and continues to expand its production and export infrastructure.
American sorghum farmers and industry partners have spent more than 15 years building a trusted commercial relationship with Chinese customers. Other agricultural sectors have demonstrated how quickly Brazil can capture market share when U.S. products face tariffs or uncertain access. If purchasing relationships and supply chains shift away from the United States, that market share may be extremely difficult to regain. Time is of the essence.
We respectfully ask that the following actions be prioritized during your meeting with President Xi.
First, we strongly support your administration's work to establish and operationalize a Board of Trade with China that would allow trade in non-sensitive goods to continue even as the United States and China address more sensitive trade issues. U.S. sorghum should be included among those non-sensitive goods.
Second, China continues to impose a 10 percent retaliatory duty on U.S. sorghum that does not apply to sorghum imported from Brazil or other competitors. This duty should be eliminated so U.S. sorghum is not placed at a competitive disadvantage and can be purchased freely by commercial firms, as well as Chinese state-owned enterprises.
Third, we ask that China's agricultural purchase commitments include a concrete and enforceable annual commitment to purchase a minimum of 5 million to 7 million metric tons of U.S. sorghum, or approximately $1.6 billion in value. This level of purchasing is consistent with established commercial trade between our countries and would provide reliable demand for American producers. True success will come when these commitments result in completed sales, vessels being loaded and grain moving from U.S. farms to customers in China.
Fourth, the one-year suspension of Section 301 port fees applied to Chinese vessels is set to expire during an important shipping period for U.S. agriculture. We are concerned that implementing these fees could increase transportation costs, disrupt shipping and ultimately pass additional expenses back to farmers. We ask that steps be taken to ensure Section 301 port fees do not disrupt or diminish U.S. sorghum exports.
In summary, U.S. sorghum farmers ask that you build on the progress of your previous meetings with President Xi by securing meaningful and enforceable purchase commitments, eliminating tariffs and trade barriers that place American farmers at a disadvantage to Brazil and other competitors, preventing shipping disruptions and prioritizing a long-term agreement that provides consistency and predictability.
National Sorghum Producers appreciates your continued attention to agriculture in U.S.-China trade negotiations. Restoring fair and reliable access to this critical market would support sorghum producers, strengthen rural communities and protect a valuable market that American farmers have spent years developing.
We look forward to positive outcomes from the upcoming summit.
Sincerely,
Amy France, Chair, National Sorghum Producers, Sorghum farmer, Scott City, Kansas
CC:
The Honorable Scott Bessent, secretary, United States Department of the Treasury
The Honorable Howard Lutnick, secretary, United States Department of Commerce
The Honorable Brooke Rollins, secretary, United States Department of Agriculture
The Honorable Jamieson Greer, United States trade representative
The Honorable Julie Callahan, chief agricultural negotiator
The Honorable Mike Crapo, chair, United States Senate Committee on Finance
The Honorable Ron Wyden, ranking member, United States Senate Committee on Finance
The Honorable John Boozman, chair, United States Senate Committee on Agriculture, Nutrition and Forestry
The Honorable Amy Klobuchar, ranking member, United States Senate Committee on Agriculture, Nutrition and Forestry
The Honorable Jason Smith, chair, United States House Committee on Ways and Means
The Honorable Richard Neal, ranking member, United States House Committee on Ways and Means
The Honorable Glenn Thompson, chair, United States House Committee on Agriculture
The Honorable Angie Craig, ranking member, United States House Committee on Agriculture
* * *
Original text here: https://sorghumgrowers.com/wp-content/uploads/2026/09/FINAL-NSP-A-Letter-to-President-Trump-US-China_Summit_9_18_26-1-1.pdf
News Release here: https://sorghumgrowers.com/2026/09/18/nsp-urges-progress-on-sorghum-trade-ahead-of-trump-xi-meeting/
[Category: Agriculture]
NRF Announces 2027 Class of Retail Voices
WASHINGTON, Sept. 23 -- The National Retail Federation posted the following news release:
* * *
NRF Announces 2027 Class of Retail Voices
September 22, 2026
NEW YORK - Today, in partnership with RETHINK Retail, the National Retail Federation debuts the 2027 class of Retail Voices by NRF, an exclusive community of standout thought leaders whose experience and insights advance the global retail industry. This year's selected Retail Voices are featured on NRF's website and will be celebrated at NRF 2027: Retail's Big Show, Jan. 10 - 12, 2027, at the Javits Convention Center in New York City.
Created ... Show Full Article WASHINGTON, Sept. 23 -- The National Retail Federation posted the following news release: * * * NRF Announces 2027 Class of Retail Voices September 22, 2026 NEW YORK - Today, in partnership with RETHINK Retail, the National Retail Federation debuts the 2027 class of Retail Voices by NRF, an exclusive community of standout thought leaders whose experience and insights advance the global retail industry. This year's selected Retail Voices are featured on NRF's website and will be celebrated at NRF 2027: Retail's Big Show, Jan. 10 - 12, 2027, at the Javits Convention Center in New York City. Createdin 2024, Retail Voices by NRF shines a spotlight on leaders and luminaries whose experience, insights and public contributions enrich the global retail industry. The 2027 class pairs returning Voices with a new group of Voices, spanning roles across retail and consumer packaged goods (CPG) and united by a shared commitment to elevating the industry through innovation and community impact.
New for 2027, the program adds a year-round community platform that keeps Voices connected beyond NRF Retail's Big Show in January. The 2027 class can connect with one another, share insights and stay engaged with the industry throughout the year -- extending the program's impact well beyond those three days.
"NRF has always championed the experts who amplify the important role retailers play in the economy and with the people they employ and the consumers they serve. The industry has a great story to tell, and Retail Voices is a direct extension of that mission. Since 2024, the program has provided a platform for the thought leaders and story tellers who help create a better understanding about our industry and the important impact it has in communities large and small. This year, we are proud to expand the program as we welcome our 2027 class: A distinguished group whose insight and influence extends across the global retail ecosystem," NRF SVP of Event Strategy Susan Newman said.
"What makes this program powerful isn't the recognition alone. It's the community it creates. Retail's best ideas rarely come from one person working in isolation. They come from leaders who share what they've learned and push each other further. This year's class reflects the depth of thinking happening across our industry, and we're honored to give these Voices a way to stay connected all year," RETHINK Retail CEO Marie Chevrier Schwartz said.
Retail Voices receive elevated access and visibility during NRF 2027: Retail's Big Show, with curated networking and thought-leadership experiences designed to inspire collaboration among retail's leading minds. The Voices will then carry that momentum forward into the new year through continued connection and community.
To engage with this year's cohort, use and follow the hashtag #RetailVoicesbyNRF and tag @National Retail Federation and @RETHINK Retail on LinkedIn and @NRF and @rethink_retail on Instagram.
* * *
About NRF
The National Retail Federation passionately advocates for the people, brands, policies and ideas that help retail succeed. From its headquarters in Washington, D.C., NRF empowers the industry that powers the economy. Retail is the nation's largest private-sector employer, contributing $5.3 trillion to annual GDP and supporting more than one in four U.S. jobs -- 55 million working Americans. For over a century, NRF has been a voice for every retailer and every retail job, educating, inspiring and communicating the powerful impact retail has on local communities and global economies. nrf.com
* * *
About RETHINK Retail
RETHINK Retail is your go-to destination for executive-led insights into the trends and innovations that are transforming the global retail landscape. Through our award-winning podcasts, fresh, original and thought-provoking content series, and partnerships with the world's leading retail events, we reach a growing audience of the top retail decision-makers and industry thought leaders. Learn more at www.rethink.industries.
* * *
URL: RETHINK Retail
* * *
Original text here: https://nrf.com/media-center/press-releases/nrf-announces-2027-class-of-retail-voices
[Category: Business]
* * *
NRF Announces 2027 Class of Retail Voices
September 22, 2026
NEW YORK - Today, in partnership with RETHINK Retail, the National Retail Federation debuts the 2027 class of Retail Voices by NRF, an exclusive community of standout thought leaders whose experience and insights advance the global retail industry. This year's selected Retail Voices are featured on NRF's website and will be celebrated at NRF 2027: Retail's Big Show, Jan. 10 - 12, 2027, at the Javits Convention Center in New York City.
Created ... Show Full Article WASHINGTON, Sept. 23 -- The National Retail Federation posted the following news release: * * * NRF Announces 2027 Class of Retail Voices September 22, 2026 NEW YORK - Today, in partnership with RETHINK Retail, the National Retail Federation debuts the 2027 class of Retail Voices by NRF, an exclusive community of standout thought leaders whose experience and insights advance the global retail industry. This year's selected Retail Voices are featured on NRF's website and will be celebrated at NRF 2027: Retail's Big Show, Jan. 10 - 12, 2027, at the Javits Convention Center in New York City. Createdin 2024, Retail Voices by NRF shines a spotlight on leaders and luminaries whose experience, insights and public contributions enrich the global retail industry. The 2027 class pairs returning Voices with a new group of Voices, spanning roles across retail and consumer packaged goods (CPG) and united by a shared commitment to elevating the industry through innovation and community impact.
New for 2027, the program adds a year-round community platform that keeps Voices connected beyond NRF Retail's Big Show in January. The 2027 class can connect with one another, share insights and stay engaged with the industry throughout the year -- extending the program's impact well beyond those three days.
"NRF has always championed the experts who amplify the important role retailers play in the economy and with the people they employ and the consumers they serve. The industry has a great story to tell, and Retail Voices is a direct extension of that mission. Since 2024, the program has provided a platform for the thought leaders and story tellers who help create a better understanding about our industry and the important impact it has in communities large and small. This year, we are proud to expand the program as we welcome our 2027 class: A distinguished group whose insight and influence extends across the global retail ecosystem," NRF SVP of Event Strategy Susan Newman said.
"What makes this program powerful isn't the recognition alone. It's the community it creates. Retail's best ideas rarely come from one person working in isolation. They come from leaders who share what they've learned and push each other further. This year's class reflects the depth of thinking happening across our industry, and we're honored to give these Voices a way to stay connected all year," RETHINK Retail CEO Marie Chevrier Schwartz said.
Retail Voices receive elevated access and visibility during NRF 2027: Retail's Big Show, with curated networking and thought-leadership experiences designed to inspire collaboration among retail's leading minds. The Voices will then carry that momentum forward into the new year through continued connection and community.
To engage with this year's cohort, use and follow the hashtag #RetailVoicesbyNRF and tag @National Retail Federation and @RETHINK Retail on LinkedIn and @NRF and @rethink_retail on Instagram.
* * *
About NRF
The National Retail Federation passionately advocates for the people, brands, policies and ideas that help retail succeed. From its headquarters in Washington, D.C., NRF empowers the industry that powers the economy. Retail is the nation's largest private-sector employer, contributing $5.3 trillion to annual GDP and supporting more than one in four U.S. jobs -- 55 million working Americans. For over a century, NRF has been a voice for every retailer and every retail job, educating, inspiring and communicating the powerful impact retail has on local communities and global economies. nrf.com
* * *
About RETHINK Retail
RETHINK Retail is your go-to destination for executive-led insights into the trends and innovations that are transforming the global retail landscape. Through our award-winning podcasts, fresh, original and thought-provoking content series, and partnerships with the world's leading retail events, we reach a growing audience of the top retail decision-makers and industry thought leaders. Learn more at www.rethink.industries.
* * *
URL: RETHINK Retail
* * *
Original text here: https://nrf.com/media-center/press-releases/nrf-announces-2027-class-of-retail-voices
[Category: Business]
Investment Company Institute Issues Letter to SEC Secretary Countryman
WASHINGTON, Sept. 23 (TNSletter) -- The Investment Company Institute issued the following letter to Securities and Exchange Commission Secretary Vanessa A. Countryman:
* * *
Here is the text of the letter:
September 21, 2026
Ms. Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
Re: Electronic Delivery of Information Under the Federal Securities Laws; File Number S7-2026-25
Dear Ms. Countryman:
The Investment Company Institute1 strongly supports the Securities and Exchange Commission (SEC or Commission) proposal to modernize the ... Show Full Article WASHINGTON, Sept. 23 (TNSletter) -- The Investment Company Institute issued the following letter to Securities and Exchange Commission Secretary Vanessa A. Countryman: * * * Here is the text of the letter: September 21, 2026 Ms. Vanessa A. Countryman Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Re: Electronic Delivery of Information Under the Federal Securities Laws; File Number S7-2026-25 Dear Ms. Countryman: The Investment Company Institute1 strongly supports the Securities and Exchange Commission (SEC or Commission) proposal to modernize theframework for electronic delivery (e-delivery) of information under the Federal securities laws, including by permitting e-delivery as the default method of delivery.2 This proposal is an important and overdue step toward aligning the Commission's delivery framework with how investors communicate, access information, and manage their financial lives today. ICI has long advocated for a default e-delivery framework, and we commend the Commission and its staff for advancing a proposal that would benefit investors, reduce unnecessary costs, and preserve meaningful investor choice.
The Commission's existing e-delivery framework consists largely of guidance first issued in 1995. Since then, electronic communications have become ubiquitous, investor expectations and preferences have changed dramatically, and funds and other market participants have developed secure and effective e-delivery practices. Meanwhile, the regulatory framework has not kept pace. The proposal would largely close that gap by permitting covered entities to deliver required information electronically by default, while maintaining important safeguards, including allowing investors to opt into paper delivery at any time at no cost, protecting investors' personal financial information, and requiring funds3 and other covered entities to take reasonable steps to remedy failed electronic deliveries.
We strongly support the core features of the proposal. And in our view, the proposal's economic analysis represents a reasonable and good faith attempt to quantify e-delivery's net benefits. In fact, we believe the realized cost savings of this rulemaking are likely to be higher than the SEC's estimate reflects.
At the same time, we recommend targeted changes to ensure that any final rule remains sufficiently flexible, operationally workable, and technology neutral, and delivers e-delivery's full benefits to shareholders. In particular, we recommend that the Commission:
* Permit additional delivery methods, including "access equals delivery" and "paper notice and access" delivery for select fund communications;
* Avoid prescriptive requirements that could undermine the rule's technology-neutral and evergreen objectives;
* Clarify how the rule applies to fund shares held through intermediaries;
* Permit more practical approaches to statements of availability, direct delivery, transition notices, paper copy requests, and failed delivery remediation;
* Retain the existing notice and access framework for proxy materials;
* Adopt the proposed exemption from the E-SIGN Act consent requirements; and
* Reform the New York Stock Exchange (NYSE) processing fee framework, without which fund investors will not realize the full benefits of e-delivery.
With these modifications, Regulation E-Delivery can provide a modern and durable framework that better reflects current technology and investor behavior, while protecting investor choice and reducing costs borne by fund shareholders.
I. ICI Strongly Supports Default E-Delivery and Broadly Supports Proposed Regulation E-Delivery.
We strongly support the proposal's core premise--that e-delivery should be the default delivery mechanism for federally-required securities information. Our November 2025 letter4 discussed e-delivery's many benefits for funds and their shareholders, including:
* Better aligning with evolving investor preferences;
* Enhancing investor protections and the investor experience;
* Producing cost savings for funds and shareholders; and
* Reducing waste and supply chain concerns.
We commend the Commission for proposing a default e-delivery framework that recognizes these benefits and is broadly consistent with bipartisan proposed Congressional legislation5 and ICI's recommendations. We strongly support the proposed transition from a default paper environment (requiring investors to opt in to e-delivery) to a default e-delivery environment (permitting investors to opt in to paper delivery).
We also broadly support:
* Seeking to adopt a technology neutral and evergreen final rule;
* Permitting (not requiring) the use of e-delivery;
* Maintaining important investor protections, including allowing investors to continue to opt in to paper delivery at any time;
* Safeguarding covered information containing personal financial information (PFI);
* Requiring covered entities (e.g., funds) to take reasonable steps to remediate failed deliveries; and
* Providing shareholders who will be transitioned from paper to e-delivery with notice of this change, along with ample time to request paper delivery if that is their preference.
We discuss these concepts further below. In doing so, we make targeted recommendations and offer operational insights to further improve the Commission's thoughtful proposal. In general, we support the proposal and greatly appreciate the Commission's and staff's work on this important topic.
II. Regulation E-Delivery Should Permit Broad Delivery Flexibility to Ensure that It Remains Cost-Effective, Evergreen, and Technology Neutral.
We generally support the two proposed methods of e-delivery: direct delivery and statements of availability. We request, however, that the Commission permit other forms and methods of e-delivery. In all methods of e-delivery, including those discussed in this subsection, we support allowing covered recipients to opt out of e-delivery at any time.6 Given that this paper option will exist, we support broad flexibility in the method of e-delivery, and we recommend two additional methods of e-delivery below.
We also encourage the Commission to consider whether the proposed requirements are truly technology neutral and evergreen. For example, the proposal would require a variety of prescriptive disclosures to be included in direct deliveries and statements of availability. While the disclosures are generally workable in an email (or other types of electronic communication that can accommodate a significant amount of text), they are less practical in other communications (e.g., a text message to a mobile phone). Greater flexibility would potentially enable covered entities to evolve their e-delivery practices with technology.7 We also stress that the Commission's technology-neutral approach should avoid imposing a separate delivery framework based on the technology used. We believe that the controlling principles should be whether the delivery method satisfies any final rule's functional requirements, including providing notice, reasonable access, appropriate safeguards for PFI, and a reliable means of updating the recipient's electronic address.
A. The Commission Should Permit "Access Equals Delivery" For Certain Types of Covered Information.
The proposal explains that the Commission considered an "access equals delivery" model for e-delivery, whereby "an issuer or intermediary would post some or all of its regulatory disclosures and reports online, rather than delivering them directly (or a notice of availability directly) to investors and other recipients of information."8 The Commission asks whether it should permit access equals delivery for certain regulatory documents, such as fund prospectuses and shareholder reports, and, if so, what regulatory documents should be included in this approach.9 The Commission also asks whether this approach could be based on the covered recipient.10
We recommend that the Commission permit an access equals delivery approach for fund-level reporting and disclosures that do not change based on the covered recipient. This would include prospectuses (including summary prospectuses), statements of additional information (if requested by the shareholder), certain registration statement supplements (but see footnote 11 below), annual and semiannual shareholder reports, and other fund-level regulatory notices, such as Rule 19a-1 notices, repurchase notices, and tender offer schedules. Under this approach, investors would be informed at the time of purchase that routine updates to these documents will be available on the fund's website, and, as with other permitted methods of delivery under proposed Regulation E-Delivery, investors would be able to request paper copies or opt into paper delivery at any time.11 Such an approach would prevent routine updates from overwhelming investors while still providing access to the most accurate and up-to-date information.
Access equals delivery would dramatically reduce costs paid by funds and ultimately shareholders. As discussed below, the ongoing imposition of high and recurring processing fees (including so-called suppression fees, or preference management fees) would remain an unjustifiable drag on the benefits of e-delivery. While it is not clear if, or how, vendors will adjust processing fees in light of any final Regulation E-Delivery, permitting access equals delivery would avoid preference management fees altogether for the applicable fund documents. This would result in significant additional savings for investors and no loss of information.12
If the Commission declines to permit access equals delivery for all fund regulatory documents, we recommend that the Commission permit it for targeted categories of documents, and we believe that the case for semiannual shareholder reports and Rule 19a-1 notices is especially strong. The Commission previously considered allowing semiannual reports to be delivered in this manner, and we recommended that the Commission do so at that time.13 We noted that this approach would be consistent with the Commission's preference for layered disclosure. We also note that the semiannual shareholder report may be less informative to shareholders monitoring their investments than the annual shareholder report because it covers only six months and need not include performance information or a discussion of investment strategies and techniques that a fund adviser employs. In addition, the six-month period covered by a semiannual report is also covered by the subsequent annual report, which could continue to be "pushed" to shareholders under this approach. And similar to semiannual shareholder reports,
Rule 19a-1 notices provide interim information.14 All shareholders would benefit from the cost savings associated with permitting even just select categories of fund documents to use an access equals delivery model. Finally, we would note that access equals delivery is consistent with the SEC's recent proposal to eliminate delivery of annual reports to security holders for companies that have a Form 10-K already on file and accessible on EDGAR.15
Whether or not the Commission permits access equals delivery for certain categories of documents, we also encourage the Commission to permit (but not require) access equals delivery for all types of covered information for covered recipients that are institutional investors due to the nature of the customer relationship. Institutional investors generally have sophisticated processes for monitoring and reviewing updated fund information, and they are capable of (and comfortable with) "pulling" updated information. In addition, institutional investors may request information to be packaged in a specific way that does not necessarily align with the regulatory delivery schedule. In such circumstances, it is unnecessary to also "push" the information out to institutional investors on the standard regulatory schedule.
B. The Commission Should Permit "Paper Notice and Access" Delivery.
The Commission also considered proposing "an approach whereby, if a covered entity does not have a covered recipient's electronic address, the covered entity could instead send a paper notification alerting such covered recipient that covered information is available online."16 The SEC opted against this because "[a] covered recipient who has declined even to provide an electronic address may be relatively more likely to prefer to receive covered information in paper format and may be less likely to act on a postcard or other paper delivery informing the covered recipient that covered information is available online."17
We respectfully disagree with the Commission's rationale for two reasons and recommend that it permit a form of paper notification of the online availability of covered information (referred to herein as "paper notice and access"). First, the SEC assumes that, because a shareholder has not provided an electronic address, they are more likely to prefer paper delivery. We do not believe this is necessarily true. For example, many "legacy" shareholders may have purchased variable insurance products decades ago, before the widespread use of the internet or smartphones.18 So too with fund shareholders, who may have established their accounts many years ago. These shareholders may not have provided an electronic address when they purchased their product or opened their account because electronic communications did not exist or were not common at that time. In these cases, there was no "choice," and the SEC should not infer from the absence of an electronic address a preference for paper.
Second, under a paper notice and access option, shareholders could still request paper copies and/or opt to receive full paper delivery at any time. The Commission could subject these shareholders to a similar transition process as proposed for shareholders who have provided an electronic address. The transition notices, as well as the ongoing paper postcards, would give these shareholders sufficient, ongoing opportunities to request paper.
The Commission previously adopted this approach for shareholder reports under Investment Company Act Rule 30e-3.19 The SEC stated in that adopting release that "the rule accommodates the preferences of all investors regarding their preferred means of communication--whether they wish to receive reports in paper or electronically, or simply to be notified that the reports are available online."20 The SEC further explained:
We believe [the delivery option] will improve investors' ability to access and use this information (for example, by providing investors with access to at least a full year of complete portfolio holdings information in one location), while reducing expenses associated with printing and mailing that are borne by funds, and ultimately, by their investors.21
Although the SEC rescinded Rule 30e-3 for open-end funds in 2022, its rationale had nothing to do with insufficient shareholder access to reports.22 Rather, the Commission had concurrently adopted a new and much shorter "tailored shareholder report," and changed its analysis of the potential costs and benefits of the rule. We continue to disagree with the SEC's rescission of Rule 30e-3 for open-end funds and its rationale for doing so.23 This proposal would impose a binary approach to fund communications: either full paper (which, especially in the case of proxy materials and variable insurance product disclosure documents can be quite voluminous) or electronic delivery to an electronic address. We see paper notice and access as a useful bridge between the two, particularly for older accounts.
We therefore recommend that the Commission permit paper notice and access delivery of all types of covered information, including those containing PFI, as this method would be analogous to the proposed statement of availability method of delivery. The Commission could require that paper notices meet the same general requirements as proposed for the electronic statement of availability method of delivery.
If the Commission declines to add a paper notice and access option as described above, we urge the Commission to: (i) retain Rule 30e-3 for entities that still may rely on it today; and (ii) reinstate a Rule 30e-3-like option for mutual fund and ETF delivery of shareholder reports.24 In general, we support broad flexibility with respect to delivery options, particularly where, as proposed, shareholders always have the option of requesting paper.
III. ICI Recommends Targeted Changes to Deliver Additional Benefits to Shareholders.
As noted above, we generally support the proposed Regulation E-Delivery framework. We offer recommendations below to ensure that any final rule is operationally feasible and appropriately balances regulatory burdens and costs with benefits to shareholders.
A. Definitions of "Covered Entity" and "Covered Information"
a. The Commission Should Confirm the Application of Regulation E-Delivery to the Delivery of Fund Documents for Shares Held Through an Intermediary.
Registered fund shares are commonly held through intermediaries (e.g., broker-dealers, retirement plan recordkeepers, nominees). Funds generally do not have visibility into the identity or delivery preferences of such underlying shareholders, whose shares are often held in an omnibus account. Currently, when a fund has prepared information for delivery to shareholders, the fund will alert applicable intermediaries to the availability of the covered information. The intermediary then must deliver those materials to its customers (the beneficial owners of the fund shares). That delivery is typically handled by a fulfillment vendor, which maintains records of the shareholders' addresses (including electronic addresses) and delivery preferences. The fund then receives an invoice from the fulfillment vendor, alerting it to the delivery's completion. Funds today generally do not otherwise oversee or supervise the delivery of fund materials to shareholders who hold their shares through intermediaries.
Any final e-delivery regulation should not interfere with these practices or expectations. We request that the Commission clarify and confirm that, under any final regulation, such intermediaries are "covered entities" with respect to the delivery of fund covered information and therefore have an obligation to meet the rule's technical requirements with respect to e-delivery of fund covered information.
b. The Commission Should Confirm the Application of Regulation E-Delivery to Required Disclosures Routinely Fulfilled by a Fund's Transfer Agent.
Although most fund shareholders hold their shares through an intermediary, many hold shares directly with a fund. Currently, a fund's transfer agent delivers documents to the fund's direct shareholders in generally the same way (absent the imposition of processing fees, as discussed below) that an intermediary would for its customers. Transfer agents also send to their shareholders trade confirmations and account statements, typically applying the standards applicable to broker-dealers, including Rule 10b-10 under the Securities Exchange Act of 1934 (Exchange Act) and FINRA Rule 2231 (Customer Account Statements).
The proposal explicitly lists transfer agents as "covered entities"25 and lists certain examples of covered information they are obligated to deliver under the Federal securities laws.26 However, these examples do not explicitly include delivering trade confirmations to direct-at-fund accounts (despite transfer agents generally applying Rule 10b-10). We request that the Commission confirm that these types of required documents would be considered "covered information" and that transfer agents could rely on any final rule to electronically deliver such required documents. Shareholders may be confused if certain fund documents are excluded from electronic delivery, simply due to a technical gap in the Commission's definition of covered information.
B. Definition of "Electronic Address"
The proposal would permit covered entities to deliver covered information electronically by default, subject to certain conditions, to an "electronic address that the covered recipient provides (or accepts to use) to receive covered information."27 The proposal defines "electronic address" to mean "an identifier used to communicate with a covered recipient electronically, including: an email address; a mobile phone number; or any other means of electronic communication capable of receiving electronic delivery pursuant to an electronic delivery method [that the rule sets forth] and alerting a covered recipient that covered information is available."28
We commend the Commission for seeking to define "electronic address" in a technology neutral and evergreen way. This is crucial to preserve the usefulness of any final regulation as technology continues to rapidly (and unpredictably) evolve. We encourage the Commission to ensure that any final definitions are as flexible as possible and offer comments to that end in this subsection. As part of these efforts, we urge the Commission to construe the definition of electronic address--including its "alerting" requirement--broadly to accommodate future technologies and means of delivery. We comment on two other aspects of this concept below.
a. The Commission Should Permit Covered Entities to Use an Electronic Address Provided by an Affiliated Entity or Third Party.
Footnote 118 of the proposal states that, if a covered entity receives an electronic address from an affiliated entity or from a third party, this "generally would not meet the requirement that the electronic address be provided by a covered recipient to receive covered information, and the proposed rule would not permit this covered entity to commence e-delivery to this covered recipient by providing a disclosure of e-delivery to this electronic address."29 We strongly disagree with this proposed position.
The Commission should permit covered entities to use electronic addresses obtained and provided by affiliates or third parties where the covered recipient has provided or accepted for use that electronic address to receive covered information. For example, an appropriately licensed insurance agent may sell a variable insurance contract to a client and obtain the client's email address as part of the application. The agent may then pass the email address along to the issuer. In this situation, the issuer should be permitted to use the electronic address collected by the agent or other intermediary for e-delivery because the electronic address was provided to receive covered information.
Or a registered investment adviser may deliver covered information (such as Form ADV Part 2 brochures, brochure supplements, privacy notices, and other disclosures) to advisory clients, which may include clients in third-party sponsored retail SMA and wrap fee programs. For such arrangements, the Commission should permit a covered entity to rely on an electronic address obtained by the third-party sponsor, particularly where: (i) the third party obtained the address directly from the covered recipient; and (ii) the recipient was informed by the third-party sponsor that the address may be used by other covered entities to deliver their own covered information. These conditions should also satisfy the requirement that the electronic address have been "provided" or "accepted for use" to receive covered information.
Covered entities may also periodically retrieve updated electronic addresses during the course of complying with other regulatory obligations, such as shareholder searches performed pursuant to Rule 17Ad-17 under the Exchange Act.30 Regulation E-Delivery should permit use of these updated electronic addresses, as long as a shareholder has not opted into paper delivery pursuant to any final rule.
b. The Commission Should Clarify that the "Provided" or "Accepted for Use" Standard Does Not Apply to the Proposed Transition Process.
The Commission should confirm and clarify that the requirement that an electronic address be "provided" or "accepted for use" to receive covered information does not apply in the proposed transition process for shareholders who have previously provided an electronic address but currently receive paper. A fund may have an electronic address on file for an investor but may not have tracked how it received it.
We recommend that, in order to fully realize the potential and purpose of the proposal, a fund be permitted to transition any shareholder for whom the fund has an electronic address, regardless of how that electronic address was obtained and recorded in the fund's systems. Such shareholders are adequately protected by the proposed transition process and can continue to receive paper if that is their preference. Such shareholders can also provide an alternate electronic address at any time.
C. Definition of "Personal Financial Information"
The proposal would impose stricter e-delivery requirements for covered information that contains PFI and defines PFI to mean "information specific to a covered recipient's personal financial matters, such as an account number or details regarding a specific securities transaction."31 The examples in the proposed definition are intended to be nonexclusive. We understand that documents such as prospectuses and shareholder reports would not be considered to contain PFI, but trade confirmations would.
We generally agree with the Commission's proposed approach to safeguard materials containing PFI. Funds today typically e-deliver these materials through a statement of availability, generally consistent with the proposal. We request, however, that the Commission clarify whether certain information constitutes PFI. For example, some funds routinely include text in their statements of availability that a document is "a trade confirmation for [the recipient's] sale of [XYZ] stock." We do not believe that this language puts shareholder privacy at risk, and we understand that recipients of these short explanatory statements generally find them helpful. It is unclear, however, whether such a description could continue to be included in a statement of availability under the proposal, because the definition of PFI is potentially broad, and it appears that PFI may be provided only behind reasonable safeguards (e.g., a secure login). We request that the Commission clarify that such a high-level general statement would not constitute PFI and may continue to be included in a statement of availability.
D. Statements of Availability and Direct Delivery
ICI generally supports the proposed statement of availability e-delivery option, subject to targeted changes to mitigate operational burdens and allow funds to best serve their shareholders.
a. The Commission Should Permit Statements of Availability to Link to a Landing Page.
The proposal would require that a statement of availability include "a website address where the covered information is available" that: (i) for covered information without PFI, "leads . . . directly to the covered information;" and (ii) for covered information with PFI, "leads . . . directly to the covered information immediately after the covered recipient completes [a process reasonably designed to safeguard the PFI]".32 The Commission states that "[t]his requirement is designed to facilitate easy access to the covered information . . . and maximize the likelihood that covered recipients review the covered information"33 and suggests that a landing page with links to multiple documents would not satisfy the proposed requirement.34
We strongly encourage the Commission to provide more flexibility with respect to the hyperlink requirements, including permitting the use of landing pages. Hyperlinks are commonly used in e-delivery today, and funds take different approaches in using them. Some funds provide direct links for fund-level regulatory documents (i.e., documents that are not account-specific, such as prospectuses and shareholder reports), but others may not.
While the proposed approach may be operationally more feasible for fund-level regulatory documents, the proposal is not consistent with current fund industry practice for account-level documents (for example, trade confirmations). Today, links provided for such documents typically take the recipient to a login page. Once the investor logs in, they are generally directed to a personalized dashboard landing page or a documents/disclosures landing page.
It is operationally challenging to render a copy of the account-level document immediately upon the investor logging into their online account. Building out this capability would require significant costs and programming, which may reduce the benefits of the proposal to both covered entities and recipients. Furthermore, there is no indication that today's common practices (i.e., directing investors to a login page, from which they can log in and navigate to the information) have caused issues for investors.
Accordingly, the Commission should permit funds to direct shareholders to a landing page where relevant disclosures and documents can be identified and accessed, so long as the shareholder can reasonably locate the desired information.
b. The Commission Should Permit Statements of Availability and Direct Deliveries to Include Other Information.
The proposal would require that "a statement of availability or direct delivery of covered information must be delivered separately from communications that are not covered information, except as otherwise provided under the Federal securities laws."35 The Commission explains that this requirement is "designed to help ensure that the e-delivery is not lost or buried in other communications or marketing materials" and specifically that "other documents do not obscure the regulatorily required covered information."36
We recommend that the Commission permit statements of availability and direct deliveries to include other non-covered information. We understand the Commission's concerns about marketing materials and other materials that may obscure the covered information; however, we believe that there are many legitimate instances in which a covered entity could include non-covered information in a way that would not obscure the covered information and would benefit covered recipients. For example, funds may be required under the Internal Revenue Code to deliver certain tax documents that are not "covered information" under the proposal. As proposed, funds would not be permitted to deliver those tax documents with covered information. Bundling covered and non-covered information, while still clearly and conspicuously highlighting the former, would reduce the number of electronic communications (but not the overall amount of information) and their related costs and mitigate recipients' administrative burdens. Other possible examples of when a fund may wish to combine a statement of availability or direct delivery with other non-covered information include the delivery of: (i) certain proxy-related materials;37 and (ii) an annual report to shareholders, accompanied by an annual CEO letter.
The proposed restriction would increase electronic deliveries and therefore costs for funds and shareholders. We encourage the Commission to allow e-delivery of covered information to be combined with other non-covered information, as long as the covered information is clear and prominent.
E. Covered Recipient Requests for Paper Copies
The proposal would require that covered entities "send, free of charge, one paper copy of any of the covered information . . . delivered through electronic delivery . . . during the period the covered entity is required to retain the covered information under the Federal securities laws, or in the two years preceding the date of the covered recipient's request if there is no such requirement, to any such covered recipient requesting such a copy."38 The Commission explains that this requirement "would facilitate ease of access to and review of covered information by covered recipients through their preferred method."39
The proposed requirements would also "allow covered recipients to choose which types of covered information are provided in paper format or electronically on a document-by-document basis,"40 and the Commission solicits comment on whether covered entities should be allowed to offer e-delivery on an "all-or-nothing" basis or a "document-by-document" basis. We offer comments on these proposed requirements below.
a. The Commission Should Not Require Covered Entities to Provide Paper Copies of Historical Covered Information Free of Charge.
We generally support allowing covered recipients to request one paper copy of current covered information that was delivered electronically free of charge. We strongly recommend, however, that the Commission not require covered entities to provide: (i) multiple paper copies of current covered information; or (ii) any paper copies of historical covered information.41 If covered entities voluntarily choose to provide (or if the Commission insists they provide) these paper copies, firms should be able to charge reasonable fees to recoup costs incurred in meeting any such requests.
Shareholders often request multiple historical documents across multiple periods for themselves or third parties, such as accountants, lawyers, or auditors, and are often assessed, and willing to pay a fee for, these exceptional requests. These requests, and other requests for paper copies of historical covered information, should fall outside the proposed requirement to provide paper copies "free of charge." It is unreasonable to expect covered entities to provide large quantities of documents or historical covered information for free. Responding to a request to conduct a lookback and production (or reproduction) of printed materials may impose certain identifiable costs.42
Furthermore, funds should not be required to provide paper copies of stale registration statements, shareholder reports, or proxy statements. Requiring that funds provide these older documents (with outdated information on key matters like performance and expenses) could cause investor confusion and significant fund administrative burden. To the extent an investor wants access to an older, stale regulatory document, such documents remain available on the SEC's Edgar website.
Additionally, three business days may be insufficient to fulfill print requests, particularly for requests that contain historical documents or multiple current documents. We recommend that the Commission instead require that paper copies be provided (subject to the scoping comments above) "promptly" or "without unreasonable delay," rather than requiring a specific number of days. To the extent covered entities provide paper copies of historical documents voluntarily as a courtesy, the Commission should not mandate a particular timeline.
b. The Commission Should Let Covered Entities Decide Whether to Offer E-Delivery on a Document-by-Document Basis.
As noted above, the Commission requests comment on whether it should permit covered entities to offer e-delivery on an "all-or-nothing" basis or whether it should, as proposed, require that recipients be able to elect e-delivery on a "document-by-document" basis. We strongly urge the Commission to let covered entities decide this. There are many possible approaches, and we believe that this is (and should remain) a business and investor-relations decision, rather than a regulatory requirement.
Depending on the business type, services, and products offered, a covered entity's covered recipients may have different preferences and expectations. For example, some funds may choose to (and may today) offer e-delivery on a document-by-document basis, but some may instead choose to offer e-delivery on an all-or-nothing or a category-by-category basis (e.g., shareholders may choose e-delivery for fund-level regulatory documents such as prospectuses and shareholder reports but may choose paper delivery for tax documents and/or trade confirmations). We understand that this category-specific approach is common for funds. We also understand that, for funds that do not already offer e-delivery on a document-by-document basis, building this capability would be extremely burdensome and would likely increase costs for funds and shareholders. Funds are best positioned to determine which options will best serve their shareholders and appropriately balance costs.
c. The Commission Should Permit Electronic-Only Products, Services, and Account Types.
The proposal does not discuss whether certain products, services or account types may be offered on an electronic-only basis. The SEC should acknowledge that firms may offer digital only products and services, wherein electronic delivery is an explicit condition of the product, service, or account type and is agreed to by the customer at the time of purchase.
F. Remediation of Failed Deliveries
ICI supports requiring covered entities to have written policies and procedures reasonably designed to identify and remediate failed e-delivery. We also generally agree that, if a covered entity identifies an e-delivery failure, it should promptly take remediation steps.43 We strongly support the Commission's statements that "the proposed remediation provisions are not intended to require covered entities to monitor account engagement, clickthrough rates, whether a message was opened, or reviewed" and that, "instead, the proposed requirements aim to address whether there was an actual failure to deliver."44
Funds are already subject to document delivery requirements, and many already have applicable policies and procedures. We request in any final rule that the Commission confirm and clarify that these existing policies and procedures, if consistent with the final requirements, would suffice.
The Commission should also confirm and clarify that covered entities have flexibility with respect to reasonable remediation approaches. Covered entities are best positioned to determine what constitutes a reasonable approach to monitoring for, and remediating, e-delivery failures, and a covered entity may take different reasonable approaches to addressing email "bounce-backs," mobile message delivery failures, and other e-delivery failures. Such approaches may not include immediately switching the shareholder to paper delivery and could, instead, include attempting to deliver to an alternate electronic address on file. If that and other reasonable alternatives also fail, it would be reasonable for a covered entity to temporarily suspend e-delivery for that recipient while the covered entity contacts the shareholder and obtains updated delivery instructions. We believe this is consistent with the Commission's views, which recognize that "[r]ather than immediately transitioning the covered recipient to paper delivery on a global basis . . ., the covered entity could send the covered information in paper while attempting to re-establish a valid or functional electronic address for future deliveries."45 We request that the Commission affirm this view and clarify that funds have broad flexibility to design their reasonable remediation policies and procedures.
G. Transition Process for Shareholders Who Have Provided Electronic Addresses But Currently Receive Paper
The proposal includes an e-delivery transition process for covered recipients who currently receive paper but who have provided an electronic address. A covered entity would provide such covered recipients two paper notices: the first at least 180 days prior to the transition and the second 30 days prior to the transition.
While we believe that there are many reasonable notice and transition frameworks, we generally support this proposed transition process, with the modifications discussed below. We also support an expansive definition of "covered recipient receiving paper," as proposed.46
a. The Commission Should Consider Shortening the Notice Timeline.
The proposed transition notice timeline (i.e., an initial notice at least 180 days prior, and a follow-up notice 30 days prior) is operationally feasible, and we appreciate that the Commission has proposed a timeline that is consistent with the recommendation in our November 2025 letter.
Upon further discussion with members, we recommend that the Commission consider shortening this period to require an initial notice at least 90 days prior to the transition47 and a follow-up notice approximately 30 days prior to the transition. We now believe that a shorter transition period--still with two notices--would better alert shareholders to the pending change and allow them to opt for paper. We also believe that, operationally, it may be challenging to deliver the follow-up notice precisely 30 days prior to the transition, and we request that the Commission affirm that covered entities need only provide the follow-up notice "approximately" (or "no later than" or some similarly flexible formulation) 30 days in advance.
Whether or not the Commission ultimately maintains the proposed timeline, we encourage the Commission to allow covered entities to send transition notices electronically to shareholders who are already receiving some covered information electronically, rather than on paper, and within a shorter notice timeline, such as 30 days total. These shareholders are already accustomed to receiving information electronically and therefore have some level of comfort with it. And in any event, they still may opt for paper.
b. Transition Notices Need Not Include the Covered Recipient's Full Electronic Address.
The initial and follow-up transition notices would include "the electronic address that will be used to deliver covered information to the covered recipient."48 This proposed requirement presents privacy and security concerns, and we strongly recommend that the Commission eliminate it. Instead, covered entities should be permitted to describe the electronic address to be used, such as "delivery to the email address on file" or "delivery to the mobile phone number previously provided." If the Commission moves forward with the proposed requirement, the Commission must permit covered entities to redact portions of the electronic address for security and privacy purposes.
c. The Commission Should Permit Transition Notices to be Delivered with Other Information.
The proposal would require that initial and follow-up transition notices be "provided separately from other communications."49 The Commission should permit transition notices to be delivered with other information. As discussed in Section III.D.b above, funds may wish to deliver these notices with other information, while still ensuring that the notices are clear and prominent. This would allow, for example, funds to deliver transition notices with a fund's shareholder report or annual prospectus update mailing, reducing the number of shareholder communications and overall delivery costs.
H. The Commission Should Permit "Householding" of Covered Information Under Regulation E-Delivery.
The Commission has previously recognized that householding50 provides greater convenience and cost savings for funds and investors by reducing duplicate document deliveries, 51 and we support the proposed amendments that would permit householding with respect to the electronic delivery of proxy materials.52 Duplicate deliveries to an electronic address could arise where multiple investors share an electronic address (e.g., spouses set up a shared email address for managing their financial affairs, or a parent establishes an account for a minor child) or an investor has multiple accounts with the same covered entity and with duplicate holdings. In these instances, duplicate delivery wastes resources and imposes unnecessary costs on fund shareholders.
Consistent with those proposed changes, we request that the Commission confirm, under Regulation E-Delivery, funds may household prospectuses and shareholder reports delivered to a shared electronic address to the same extent they may household comparable paper deliveries.53 This would be consistent with the Commission's longstanding views on householding. We see no reason to treat electronic delivery differently from paper delivery in this respect, and we request that the Commission explicitly permit householding broadly.
IV. E-Delivery Can Enhance Investor Protections.
In our November 2025 letter, we included enhanced investor protections as an e-delivery benefit. Some commenters have raised cybersecurity-related concerns in connection with the proposal, and we respond to those concerns here.
Although the potential for fraud exists everywhere in today's world, we continue to believe that e-delivery (compared to paper) is faster and more secure in many respects. As discussed in our November 2025 letter, the speed and direct nature of electronic communications, combined with the layers of security added by log-in requirements, provides greater privacy and security than paper mail.54 Fraud risk exists across delivery channels, and paper delivery presents its own vulnerabilities, including theft, mail fraud, mis-delivery, and delayed detection of unauthorized activity. By contrast, e-delivery can support stronger safeguards by enabling pre-authentication before sensitive information is accessed and keeping documents within a protected digital environment (unless a shareholder chooses to download or print them).
In addition, although the potential for an online account to be "hacked" exists, technology also exists to detect and combat this kind of activity. Funds may utilize a combination of security messages to alert investors of account access, as well as back-end surveillance reports designed to detect suspicious online activity patterns. Today, multifactor authentication is a common fund security protocol to safeguard investor credentials. No such protective measures exist once a paper document is mailed.
Commenters have also raised concerns about the potential for increased "phishing" activity and related shareholder confusion and susceptibility to phishing attempts if e-delivery becomes the default. These concerns are important and should be thoughtfully considered. As we discussed in our November 2025 letter, funds and advisers have invested significant resources into educating investors regarding the availability of online documents and effective habits for protecting themselves against fraud.55 Funds continuously update their websites, investor communications, and security protocols in support of evolving security safeguards and investor protection, including investor alerts focused on protecting personal information from mail or online fraud, or education tailored towards protecting older investors from the risks of elder fraud. We also note that covered entities will generally have standardized communication formats and predictable delivery timelines that may help recipients determine whether a communication is legitimate.
In our view, increased use of an "access equals delivery" framework would further mitigate these risks. Shareholders could proactively access covered materials from their bookmarked, trusted financial institutions' websites, at their convenience. For materials containing sensitive information, this access would occur only after self-authentication. This approach would meaningfully reduce phishing risk because shareholders would come to expect fewer "pushed" communications from covered entities. Unexpected emails containing links would therefore stand out as atypical, encouraging shareholders to access covered materials directly through trusted websites.
Similarly, generally reducing the volume of electronic communications (such as by combining e-deliveries of covered information with other materials, or by householding) would mitigate these risks. A lower volume of notices would allow shareholders to better identify and distinguish atypical notices. Lastly, allowing firms to brand, personalize, or otherwise distinguish their notices from generic communications may help shareholders better identify legitimate messages.
V. The NYSE Processing Fee Schedule is Flawed and Should Be Scrapped or Fundamentally Reformed.
While we commend the SEC for its work on e-delivery, we strongly reiterate our concerns about the current NYSE processing fee rules and our call for reform.56 The current NYSE processing fee framework has long been controversial.57 The SEC's Investor Advisory Committee raised concerns with the status quo in 201958 and again in June 2026 as part of its fund proxy reform recommendations.59
ICI has repeatedly objected to this framework as it applies to funds and has offered multiple reform recommendations.60 We again strongly urge the Commission to reform the current processing fee framework to further reduce the costs associated with delivering documents electronically to intermediary-held accounts. For the reasons discussed below, we believe that the current processing fee framework is anticompetitive and antithetical to the Commission's goals of encouraging e-delivery.
Under NYSE rules, NYSE member organizations (e.g., broker-dealers) must deliver disclosure materials to beneficial owners, including fund shareholders, that hold shares in nominee name through an intermediary. Funds must then reimburse NYSE member organizations for out-of-pocket, reasonable, clerical, postage, and other expenses, according to the NYSE fee schedule. While the NYSE fee schedule was originally intended to ensure a fair and reasonable allocation of costs, it has failed in practice. Intermediaries--which rely on third parties to meet this delivery obligation--have no incentive to negotiate lower rates with those third parties. The parties that pay the bills--funds--are cut out of this process and have little ability to lower these expenses for the benefit of their shareholders.
Furthermore, the NYSE fee schedule has historically included a "preference management fee" (or "suppression fee") which effectively charges a per-account fee to suppress paper mailings for shareholders who have opted into e-delivery. Because this fee is charged in perpetuity, it has consistently limited the cost savings that e-delivery provides to fund shareholders. In a speech earlier this year, Commissioner Peirce stated:
"The cost savings for investors from funds (or intermediaries) not having to print and mail so many documents would increase shareholders' return on their investment, which is why they invest in the first place. As a corollary, we may need to address the rather absurd situation in which a fund must pay intermediaries higher fees not to send paper documents to investors."61
We agree.
It is unclear how processing fees and, in particular, suppression fees, will change if Regulation E-Delivery is finalized and e-delivery becomes the default. If third-party vendors continue to charge suppression fees for e-delivery, fund and investor cost savings from e-delivery would be lower than they otherwise would be. The SEC itself estimates that the "cost of the preference management fee to investment companies relying on the proposed rule to [deliver] fund proxy voting materials, shareholder reports, and prospectuses, including summary prospectuses, to covered recipients would be $20 million per year."62 This is consistent with ICI's recent estimates between $11 and 25 million for total preference management fee costs for accounts being transitioned from paper delivery to e-delivery.63
Due to the nature of the proposal, however, the SEC did not estimate the cost of existing preference management fees on accounts that already receive e-delivery. ICI has previously estimated the total current preference management fees paid by funds and shareholders to range from approximately $119 to $151 million annually, and under the current framework, funds pay these fees in perpetuity.64 If the fee structure and general vendor practices stay the same after any final rule becomes effective, this figure would increase by the SEC's estimated $20 million for new e-delivery accounts.
We continue to believe that the NYSE fee framework is ill-suited to the distribution of fund materials and that the current process of reimbursing intermediaries for forwarding fund materials creates perverse incentives and inhibits market competition. Also, this proposal would allow shareholders to request paper delivery or paper copies of materials delivered electronically free of charge. We recognize that delivery of any kind--electronic or paper-- involves costs and that the reimbursement of pure out-of-pocket expenses associated with delivering fund materials is appropriate. Still, this proposal's spirit--and in some respects, its letter--is especially hard to square with the perpetual siphoning off as much as of $151 million annually of fund assets for merely recording shareholders' delivery preferences.
ICI has previously recommended that the Commission permit funds to negotiate with vendors and eliminate the need for a fee schedule by either:
* making clear that Section 14 rules under the Exchange Act65 permit funds to choose how to deliver fund regulatory materials and require intermediaries to provide to funds or their selected agent (i.e., vendor), upon request, a data file (i) with only the shareholder information necessary for delivering these materials (ii) to be used only for such purposes; or
* allowing funds to choose how to deliver fund regulatory materials by not applying the objecting beneficial owner (OBO)/non-objecting beneficial owner (NOBO) distinction for the purpose of distributing fund regulatory materials.66
As an alternative to the bullet directly above, funds could be permitted to choose their vendors, while requiring that information about OBOs that vendors gather remain with them alone, contractually "walled off" from the funds. This would allow funds to achieve cost savings from vendor selection while still preserving the current OBO/NOBO framework. Under this approach, funds would be incentivized to negotiate lower fulfillment costs, vendors chosen by funds would be incentivized to price competitively, and intermediaries would not have to administer the fulfillment of fund materials.
Permitting funds to negotiate the fees that they pay would improve competition and lower fees. If the Commission is unwilling to act on any of the above recommendations, ICI has also recommended that the SEC itself take control of and reform the fee schedule. But again, our preferred recommendations above would remove any entity--NYSE or SEC--from the rate setting process.
We also continue to strongly encourage the Commission to consider other measures that would decrease processing fees. For example, the Commission could permit "access equals delivery" (discussed further above) for some fund document types, which would avoid the imposition of processing fees on applicable documents altogether, as it would obviate the need for distributions. Absent actual processing fee reform, reducing the number of documents and notices delivered and subject to processing fees is the only way to realize more cost savings from e-delivery.
Again, we recognize the benefits of this proposal in its current form. And we understand the appeal of moving incrementally. Still, the Commission should not allow the current NYSE fee schedule and related practices--with all of their inequities and inefficiencies--to remain as the foundation for Regulation E-Delivery.
View full text of the letter here (https://www.ici.org/sites/default/files/2026-09/26-cl-sec-edelivery-modernization-proposal.pdf)
* * *
Here is the text of the letter:
September 21, 2026
Ms. Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
Re: Electronic Delivery of Information Under the Federal Securities Laws; File Number S7-2026-25
Dear Ms. Countryman:
The Investment Company Institute1 strongly supports the Securities and Exchange Commission (SEC or Commission) proposal to modernize the ... Show Full Article WASHINGTON, Sept. 23 (TNSletter) -- The Investment Company Institute issued the following letter to Securities and Exchange Commission Secretary Vanessa A. Countryman: * * * Here is the text of the letter: September 21, 2026 Ms. Vanessa A. Countryman Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Re: Electronic Delivery of Information Under the Federal Securities Laws; File Number S7-2026-25 Dear Ms. Countryman: The Investment Company Institute1 strongly supports the Securities and Exchange Commission (SEC or Commission) proposal to modernize theframework for electronic delivery (e-delivery) of information under the Federal securities laws, including by permitting e-delivery as the default method of delivery.2 This proposal is an important and overdue step toward aligning the Commission's delivery framework with how investors communicate, access information, and manage their financial lives today. ICI has long advocated for a default e-delivery framework, and we commend the Commission and its staff for advancing a proposal that would benefit investors, reduce unnecessary costs, and preserve meaningful investor choice.
The Commission's existing e-delivery framework consists largely of guidance first issued in 1995. Since then, electronic communications have become ubiquitous, investor expectations and preferences have changed dramatically, and funds and other market participants have developed secure and effective e-delivery practices. Meanwhile, the regulatory framework has not kept pace. The proposal would largely close that gap by permitting covered entities to deliver required information electronically by default, while maintaining important safeguards, including allowing investors to opt into paper delivery at any time at no cost, protecting investors' personal financial information, and requiring funds3 and other covered entities to take reasonable steps to remedy failed electronic deliveries.
We strongly support the core features of the proposal. And in our view, the proposal's economic analysis represents a reasonable and good faith attempt to quantify e-delivery's net benefits. In fact, we believe the realized cost savings of this rulemaking are likely to be higher than the SEC's estimate reflects.
At the same time, we recommend targeted changes to ensure that any final rule remains sufficiently flexible, operationally workable, and technology neutral, and delivers e-delivery's full benefits to shareholders. In particular, we recommend that the Commission:
* Permit additional delivery methods, including "access equals delivery" and "paper notice and access" delivery for select fund communications;
* Avoid prescriptive requirements that could undermine the rule's technology-neutral and evergreen objectives;
* Clarify how the rule applies to fund shares held through intermediaries;
* Permit more practical approaches to statements of availability, direct delivery, transition notices, paper copy requests, and failed delivery remediation;
* Retain the existing notice and access framework for proxy materials;
* Adopt the proposed exemption from the E-SIGN Act consent requirements; and
* Reform the New York Stock Exchange (NYSE) processing fee framework, without which fund investors will not realize the full benefits of e-delivery.
With these modifications, Regulation E-Delivery can provide a modern and durable framework that better reflects current technology and investor behavior, while protecting investor choice and reducing costs borne by fund shareholders.
I. ICI Strongly Supports Default E-Delivery and Broadly Supports Proposed Regulation E-Delivery.
We strongly support the proposal's core premise--that e-delivery should be the default delivery mechanism for federally-required securities information. Our November 2025 letter4 discussed e-delivery's many benefits for funds and their shareholders, including:
* Better aligning with evolving investor preferences;
* Enhancing investor protections and the investor experience;
* Producing cost savings for funds and shareholders; and
* Reducing waste and supply chain concerns.
We commend the Commission for proposing a default e-delivery framework that recognizes these benefits and is broadly consistent with bipartisan proposed Congressional legislation5 and ICI's recommendations. We strongly support the proposed transition from a default paper environment (requiring investors to opt in to e-delivery) to a default e-delivery environment (permitting investors to opt in to paper delivery).
We also broadly support:
* Seeking to adopt a technology neutral and evergreen final rule;
* Permitting (not requiring) the use of e-delivery;
* Maintaining important investor protections, including allowing investors to continue to opt in to paper delivery at any time;
* Safeguarding covered information containing personal financial information (PFI);
* Requiring covered entities (e.g., funds) to take reasonable steps to remediate failed deliveries; and
* Providing shareholders who will be transitioned from paper to e-delivery with notice of this change, along with ample time to request paper delivery if that is their preference.
We discuss these concepts further below. In doing so, we make targeted recommendations and offer operational insights to further improve the Commission's thoughtful proposal. In general, we support the proposal and greatly appreciate the Commission's and staff's work on this important topic.
II. Regulation E-Delivery Should Permit Broad Delivery Flexibility to Ensure that It Remains Cost-Effective, Evergreen, and Technology Neutral.
We generally support the two proposed methods of e-delivery: direct delivery and statements of availability. We request, however, that the Commission permit other forms and methods of e-delivery. In all methods of e-delivery, including those discussed in this subsection, we support allowing covered recipients to opt out of e-delivery at any time.6 Given that this paper option will exist, we support broad flexibility in the method of e-delivery, and we recommend two additional methods of e-delivery below.
We also encourage the Commission to consider whether the proposed requirements are truly technology neutral and evergreen. For example, the proposal would require a variety of prescriptive disclosures to be included in direct deliveries and statements of availability. While the disclosures are generally workable in an email (or other types of electronic communication that can accommodate a significant amount of text), they are less practical in other communications (e.g., a text message to a mobile phone). Greater flexibility would potentially enable covered entities to evolve their e-delivery practices with technology.7 We also stress that the Commission's technology-neutral approach should avoid imposing a separate delivery framework based on the technology used. We believe that the controlling principles should be whether the delivery method satisfies any final rule's functional requirements, including providing notice, reasonable access, appropriate safeguards for PFI, and a reliable means of updating the recipient's electronic address.
A. The Commission Should Permit "Access Equals Delivery" For Certain Types of Covered Information.
The proposal explains that the Commission considered an "access equals delivery" model for e-delivery, whereby "an issuer or intermediary would post some or all of its regulatory disclosures and reports online, rather than delivering them directly (or a notice of availability directly) to investors and other recipients of information."8 The Commission asks whether it should permit access equals delivery for certain regulatory documents, such as fund prospectuses and shareholder reports, and, if so, what regulatory documents should be included in this approach.9 The Commission also asks whether this approach could be based on the covered recipient.10
We recommend that the Commission permit an access equals delivery approach for fund-level reporting and disclosures that do not change based on the covered recipient. This would include prospectuses (including summary prospectuses), statements of additional information (if requested by the shareholder), certain registration statement supplements (but see footnote 11 below), annual and semiannual shareholder reports, and other fund-level regulatory notices, such as Rule 19a-1 notices, repurchase notices, and tender offer schedules. Under this approach, investors would be informed at the time of purchase that routine updates to these documents will be available on the fund's website, and, as with other permitted methods of delivery under proposed Regulation E-Delivery, investors would be able to request paper copies or opt into paper delivery at any time.11 Such an approach would prevent routine updates from overwhelming investors while still providing access to the most accurate and up-to-date information.
Access equals delivery would dramatically reduce costs paid by funds and ultimately shareholders. As discussed below, the ongoing imposition of high and recurring processing fees (including so-called suppression fees, or preference management fees) would remain an unjustifiable drag on the benefits of e-delivery. While it is not clear if, or how, vendors will adjust processing fees in light of any final Regulation E-Delivery, permitting access equals delivery would avoid preference management fees altogether for the applicable fund documents. This would result in significant additional savings for investors and no loss of information.12
If the Commission declines to permit access equals delivery for all fund regulatory documents, we recommend that the Commission permit it for targeted categories of documents, and we believe that the case for semiannual shareholder reports and Rule 19a-1 notices is especially strong. The Commission previously considered allowing semiannual reports to be delivered in this manner, and we recommended that the Commission do so at that time.13 We noted that this approach would be consistent with the Commission's preference for layered disclosure. We also note that the semiannual shareholder report may be less informative to shareholders monitoring their investments than the annual shareholder report because it covers only six months and need not include performance information or a discussion of investment strategies and techniques that a fund adviser employs. In addition, the six-month period covered by a semiannual report is also covered by the subsequent annual report, which could continue to be "pushed" to shareholders under this approach. And similar to semiannual shareholder reports,
Rule 19a-1 notices provide interim information.14 All shareholders would benefit from the cost savings associated with permitting even just select categories of fund documents to use an access equals delivery model. Finally, we would note that access equals delivery is consistent with the SEC's recent proposal to eliminate delivery of annual reports to security holders for companies that have a Form 10-K already on file and accessible on EDGAR.15
Whether or not the Commission permits access equals delivery for certain categories of documents, we also encourage the Commission to permit (but not require) access equals delivery for all types of covered information for covered recipients that are institutional investors due to the nature of the customer relationship. Institutional investors generally have sophisticated processes for monitoring and reviewing updated fund information, and they are capable of (and comfortable with) "pulling" updated information. In addition, institutional investors may request information to be packaged in a specific way that does not necessarily align with the regulatory delivery schedule. In such circumstances, it is unnecessary to also "push" the information out to institutional investors on the standard regulatory schedule.
B. The Commission Should Permit "Paper Notice and Access" Delivery.
The Commission also considered proposing "an approach whereby, if a covered entity does not have a covered recipient's electronic address, the covered entity could instead send a paper notification alerting such covered recipient that covered information is available online."16 The SEC opted against this because "[a] covered recipient who has declined even to provide an electronic address may be relatively more likely to prefer to receive covered information in paper format and may be less likely to act on a postcard or other paper delivery informing the covered recipient that covered information is available online."17
We respectfully disagree with the Commission's rationale for two reasons and recommend that it permit a form of paper notification of the online availability of covered information (referred to herein as "paper notice and access"). First, the SEC assumes that, because a shareholder has not provided an electronic address, they are more likely to prefer paper delivery. We do not believe this is necessarily true. For example, many "legacy" shareholders may have purchased variable insurance products decades ago, before the widespread use of the internet or smartphones.18 So too with fund shareholders, who may have established their accounts many years ago. These shareholders may not have provided an electronic address when they purchased their product or opened their account because electronic communications did not exist or were not common at that time. In these cases, there was no "choice," and the SEC should not infer from the absence of an electronic address a preference for paper.
Second, under a paper notice and access option, shareholders could still request paper copies and/or opt to receive full paper delivery at any time. The Commission could subject these shareholders to a similar transition process as proposed for shareholders who have provided an electronic address. The transition notices, as well as the ongoing paper postcards, would give these shareholders sufficient, ongoing opportunities to request paper.
The Commission previously adopted this approach for shareholder reports under Investment Company Act Rule 30e-3.19 The SEC stated in that adopting release that "the rule accommodates the preferences of all investors regarding their preferred means of communication--whether they wish to receive reports in paper or electronically, or simply to be notified that the reports are available online."20 The SEC further explained:
We believe [the delivery option] will improve investors' ability to access and use this information (for example, by providing investors with access to at least a full year of complete portfolio holdings information in one location), while reducing expenses associated with printing and mailing that are borne by funds, and ultimately, by their investors.21
Although the SEC rescinded Rule 30e-3 for open-end funds in 2022, its rationale had nothing to do with insufficient shareholder access to reports.22 Rather, the Commission had concurrently adopted a new and much shorter "tailored shareholder report," and changed its analysis of the potential costs and benefits of the rule. We continue to disagree with the SEC's rescission of Rule 30e-3 for open-end funds and its rationale for doing so.23 This proposal would impose a binary approach to fund communications: either full paper (which, especially in the case of proxy materials and variable insurance product disclosure documents can be quite voluminous) or electronic delivery to an electronic address. We see paper notice and access as a useful bridge between the two, particularly for older accounts.
We therefore recommend that the Commission permit paper notice and access delivery of all types of covered information, including those containing PFI, as this method would be analogous to the proposed statement of availability method of delivery. The Commission could require that paper notices meet the same general requirements as proposed for the electronic statement of availability method of delivery.
If the Commission declines to add a paper notice and access option as described above, we urge the Commission to: (i) retain Rule 30e-3 for entities that still may rely on it today; and (ii) reinstate a Rule 30e-3-like option for mutual fund and ETF delivery of shareholder reports.24 In general, we support broad flexibility with respect to delivery options, particularly where, as proposed, shareholders always have the option of requesting paper.
III. ICI Recommends Targeted Changes to Deliver Additional Benefits to Shareholders.
As noted above, we generally support the proposed Regulation E-Delivery framework. We offer recommendations below to ensure that any final rule is operationally feasible and appropriately balances regulatory burdens and costs with benefits to shareholders.
A. Definitions of "Covered Entity" and "Covered Information"
a. The Commission Should Confirm the Application of Regulation E-Delivery to the Delivery of Fund Documents for Shares Held Through an Intermediary.
Registered fund shares are commonly held through intermediaries (e.g., broker-dealers, retirement plan recordkeepers, nominees). Funds generally do not have visibility into the identity or delivery preferences of such underlying shareholders, whose shares are often held in an omnibus account. Currently, when a fund has prepared information for delivery to shareholders, the fund will alert applicable intermediaries to the availability of the covered information. The intermediary then must deliver those materials to its customers (the beneficial owners of the fund shares). That delivery is typically handled by a fulfillment vendor, which maintains records of the shareholders' addresses (including electronic addresses) and delivery preferences. The fund then receives an invoice from the fulfillment vendor, alerting it to the delivery's completion. Funds today generally do not otherwise oversee or supervise the delivery of fund materials to shareholders who hold their shares through intermediaries.
Any final e-delivery regulation should not interfere with these practices or expectations. We request that the Commission clarify and confirm that, under any final regulation, such intermediaries are "covered entities" with respect to the delivery of fund covered information and therefore have an obligation to meet the rule's technical requirements with respect to e-delivery of fund covered information.
b. The Commission Should Confirm the Application of Regulation E-Delivery to Required Disclosures Routinely Fulfilled by a Fund's Transfer Agent.
Although most fund shareholders hold their shares through an intermediary, many hold shares directly with a fund. Currently, a fund's transfer agent delivers documents to the fund's direct shareholders in generally the same way (absent the imposition of processing fees, as discussed below) that an intermediary would for its customers. Transfer agents also send to their shareholders trade confirmations and account statements, typically applying the standards applicable to broker-dealers, including Rule 10b-10 under the Securities Exchange Act of 1934 (Exchange Act) and FINRA Rule 2231 (Customer Account Statements).
The proposal explicitly lists transfer agents as "covered entities"25 and lists certain examples of covered information they are obligated to deliver under the Federal securities laws.26 However, these examples do not explicitly include delivering trade confirmations to direct-at-fund accounts (despite transfer agents generally applying Rule 10b-10). We request that the Commission confirm that these types of required documents would be considered "covered information" and that transfer agents could rely on any final rule to electronically deliver such required documents. Shareholders may be confused if certain fund documents are excluded from electronic delivery, simply due to a technical gap in the Commission's definition of covered information.
B. Definition of "Electronic Address"
The proposal would permit covered entities to deliver covered information electronically by default, subject to certain conditions, to an "electronic address that the covered recipient provides (or accepts to use) to receive covered information."27 The proposal defines "electronic address" to mean "an identifier used to communicate with a covered recipient electronically, including: an email address; a mobile phone number; or any other means of electronic communication capable of receiving electronic delivery pursuant to an electronic delivery method [that the rule sets forth] and alerting a covered recipient that covered information is available."28
We commend the Commission for seeking to define "electronic address" in a technology neutral and evergreen way. This is crucial to preserve the usefulness of any final regulation as technology continues to rapidly (and unpredictably) evolve. We encourage the Commission to ensure that any final definitions are as flexible as possible and offer comments to that end in this subsection. As part of these efforts, we urge the Commission to construe the definition of electronic address--including its "alerting" requirement--broadly to accommodate future technologies and means of delivery. We comment on two other aspects of this concept below.
a. The Commission Should Permit Covered Entities to Use an Electronic Address Provided by an Affiliated Entity or Third Party.
Footnote 118 of the proposal states that, if a covered entity receives an electronic address from an affiliated entity or from a third party, this "generally would not meet the requirement that the electronic address be provided by a covered recipient to receive covered information, and the proposed rule would not permit this covered entity to commence e-delivery to this covered recipient by providing a disclosure of e-delivery to this electronic address."29 We strongly disagree with this proposed position.
The Commission should permit covered entities to use electronic addresses obtained and provided by affiliates or third parties where the covered recipient has provided or accepted for use that electronic address to receive covered information. For example, an appropriately licensed insurance agent may sell a variable insurance contract to a client and obtain the client's email address as part of the application. The agent may then pass the email address along to the issuer. In this situation, the issuer should be permitted to use the electronic address collected by the agent or other intermediary for e-delivery because the electronic address was provided to receive covered information.
Or a registered investment adviser may deliver covered information (such as Form ADV Part 2 brochures, brochure supplements, privacy notices, and other disclosures) to advisory clients, which may include clients in third-party sponsored retail SMA and wrap fee programs. For such arrangements, the Commission should permit a covered entity to rely on an electronic address obtained by the third-party sponsor, particularly where: (i) the third party obtained the address directly from the covered recipient; and (ii) the recipient was informed by the third-party sponsor that the address may be used by other covered entities to deliver their own covered information. These conditions should also satisfy the requirement that the electronic address have been "provided" or "accepted for use" to receive covered information.
Covered entities may also periodically retrieve updated electronic addresses during the course of complying with other regulatory obligations, such as shareholder searches performed pursuant to Rule 17Ad-17 under the Exchange Act.30 Regulation E-Delivery should permit use of these updated electronic addresses, as long as a shareholder has not opted into paper delivery pursuant to any final rule.
b. The Commission Should Clarify that the "Provided" or "Accepted for Use" Standard Does Not Apply to the Proposed Transition Process.
The Commission should confirm and clarify that the requirement that an electronic address be "provided" or "accepted for use" to receive covered information does not apply in the proposed transition process for shareholders who have previously provided an electronic address but currently receive paper. A fund may have an electronic address on file for an investor but may not have tracked how it received it.
We recommend that, in order to fully realize the potential and purpose of the proposal, a fund be permitted to transition any shareholder for whom the fund has an electronic address, regardless of how that electronic address was obtained and recorded in the fund's systems. Such shareholders are adequately protected by the proposed transition process and can continue to receive paper if that is their preference. Such shareholders can also provide an alternate electronic address at any time.
C. Definition of "Personal Financial Information"
The proposal would impose stricter e-delivery requirements for covered information that contains PFI and defines PFI to mean "information specific to a covered recipient's personal financial matters, such as an account number or details regarding a specific securities transaction."31 The examples in the proposed definition are intended to be nonexclusive. We understand that documents such as prospectuses and shareholder reports would not be considered to contain PFI, but trade confirmations would.
We generally agree with the Commission's proposed approach to safeguard materials containing PFI. Funds today typically e-deliver these materials through a statement of availability, generally consistent with the proposal. We request, however, that the Commission clarify whether certain information constitutes PFI. For example, some funds routinely include text in their statements of availability that a document is "a trade confirmation for [the recipient's] sale of [XYZ] stock." We do not believe that this language puts shareholder privacy at risk, and we understand that recipients of these short explanatory statements generally find them helpful. It is unclear, however, whether such a description could continue to be included in a statement of availability under the proposal, because the definition of PFI is potentially broad, and it appears that PFI may be provided only behind reasonable safeguards (e.g., a secure login). We request that the Commission clarify that such a high-level general statement would not constitute PFI and may continue to be included in a statement of availability.
D. Statements of Availability and Direct Delivery
ICI generally supports the proposed statement of availability e-delivery option, subject to targeted changes to mitigate operational burdens and allow funds to best serve their shareholders.
a. The Commission Should Permit Statements of Availability to Link to a Landing Page.
The proposal would require that a statement of availability include "a website address where the covered information is available" that: (i) for covered information without PFI, "leads . . . directly to the covered information;" and (ii) for covered information with PFI, "leads . . . directly to the covered information immediately after the covered recipient completes [a process reasonably designed to safeguard the PFI]".32 The Commission states that "[t]his requirement is designed to facilitate easy access to the covered information . . . and maximize the likelihood that covered recipients review the covered information"33 and suggests that a landing page with links to multiple documents would not satisfy the proposed requirement.34
We strongly encourage the Commission to provide more flexibility with respect to the hyperlink requirements, including permitting the use of landing pages. Hyperlinks are commonly used in e-delivery today, and funds take different approaches in using them. Some funds provide direct links for fund-level regulatory documents (i.e., documents that are not account-specific, such as prospectuses and shareholder reports), but others may not.
While the proposed approach may be operationally more feasible for fund-level regulatory documents, the proposal is not consistent with current fund industry practice for account-level documents (for example, trade confirmations). Today, links provided for such documents typically take the recipient to a login page. Once the investor logs in, they are generally directed to a personalized dashboard landing page or a documents/disclosures landing page.
It is operationally challenging to render a copy of the account-level document immediately upon the investor logging into their online account. Building out this capability would require significant costs and programming, which may reduce the benefits of the proposal to both covered entities and recipients. Furthermore, there is no indication that today's common practices (i.e., directing investors to a login page, from which they can log in and navigate to the information) have caused issues for investors.
Accordingly, the Commission should permit funds to direct shareholders to a landing page where relevant disclosures and documents can be identified and accessed, so long as the shareholder can reasonably locate the desired information.
b. The Commission Should Permit Statements of Availability and Direct Deliveries to Include Other Information.
The proposal would require that "a statement of availability or direct delivery of covered information must be delivered separately from communications that are not covered information, except as otherwise provided under the Federal securities laws."35 The Commission explains that this requirement is "designed to help ensure that the e-delivery is not lost or buried in other communications or marketing materials" and specifically that "other documents do not obscure the regulatorily required covered information."36
We recommend that the Commission permit statements of availability and direct deliveries to include other non-covered information. We understand the Commission's concerns about marketing materials and other materials that may obscure the covered information; however, we believe that there are many legitimate instances in which a covered entity could include non-covered information in a way that would not obscure the covered information and would benefit covered recipients. For example, funds may be required under the Internal Revenue Code to deliver certain tax documents that are not "covered information" under the proposal. As proposed, funds would not be permitted to deliver those tax documents with covered information. Bundling covered and non-covered information, while still clearly and conspicuously highlighting the former, would reduce the number of electronic communications (but not the overall amount of information) and their related costs and mitigate recipients' administrative burdens. Other possible examples of when a fund may wish to combine a statement of availability or direct delivery with other non-covered information include the delivery of: (i) certain proxy-related materials;37 and (ii) an annual report to shareholders, accompanied by an annual CEO letter.
The proposed restriction would increase electronic deliveries and therefore costs for funds and shareholders. We encourage the Commission to allow e-delivery of covered information to be combined with other non-covered information, as long as the covered information is clear and prominent.
E. Covered Recipient Requests for Paper Copies
The proposal would require that covered entities "send, free of charge, one paper copy of any of the covered information . . . delivered through electronic delivery . . . during the period the covered entity is required to retain the covered information under the Federal securities laws, or in the two years preceding the date of the covered recipient's request if there is no such requirement, to any such covered recipient requesting such a copy."38 The Commission explains that this requirement "would facilitate ease of access to and review of covered information by covered recipients through their preferred method."39
The proposed requirements would also "allow covered recipients to choose which types of covered information are provided in paper format or electronically on a document-by-document basis,"40 and the Commission solicits comment on whether covered entities should be allowed to offer e-delivery on an "all-or-nothing" basis or a "document-by-document" basis. We offer comments on these proposed requirements below.
a. The Commission Should Not Require Covered Entities to Provide Paper Copies of Historical Covered Information Free of Charge.
We generally support allowing covered recipients to request one paper copy of current covered information that was delivered electronically free of charge. We strongly recommend, however, that the Commission not require covered entities to provide: (i) multiple paper copies of current covered information; or (ii) any paper copies of historical covered information.41 If covered entities voluntarily choose to provide (or if the Commission insists they provide) these paper copies, firms should be able to charge reasonable fees to recoup costs incurred in meeting any such requests.
Shareholders often request multiple historical documents across multiple periods for themselves or third parties, such as accountants, lawyers, or auditors, and are often assessed, and willing to pay a fee for, these exceptional requests. These requests, and other requests for paper copies of historical covered information, should fall outside the proposed requirement to provide paper copies "free of charge." It is unreasonable to expect covered entities to provide large quantities of documents or historical covered information for free. Responding to a request to conduct a lookback and production (or reproduction) of printed materials may impose certain identifiable costs.42
Furthermore, funds should not be required to provide paper copies of stale registration statements, shareholder reports, or proxy statements. Requiring that funds provide these older documents (with outdated information on key matters like performance and expenses) could cause investor confusion and significant fund administrative burden. To the extent an investor wants access to an older, stale regulatory document, such documents remain available on the SEC's Edgar website.
Additionally, three business days may be insufficient to fulfill print requests, particularly for requests that contain historical documents or multiple current documents. We recommend that the Commission instead require that paper copies be provided (subject to the scoping comments above) "promptly" or "without unreasonable delay," rather than requiring a specific number of days. To the extent covered entities provide paper copies of historical documents voluntarily as a courtesy, the Commission should not mandate a particular timeline.
b. The Commission Should Let Covered Entities Decide Whether to Offer E-Delivery on a Document-by-Document Basis.
As noted above, the Commission requests comment on whether it should permit covered entities to offer e-delivery on an "all-or-nothing" basis or whether it should, as proposed, require that recipients be able to elect e-delivery on a "document-by-document" basis. We strongly urge the Commission to let covered entities decide this. There are many possible approaches, and we believe that this is (and should remain) a business and investor-relations decision, rather than a regulatory requirement.
Depending on the business type, services, and products offered, a covered entity's covered recipients may have different preferences and expectations. For example, some funds may choose to (and may today) offer e-delivery on a document-by-document basis, but some may instead choose to offer e-delivery on an all-or-nothing or a category-by-category basis (e.g., shareholders may choose e-delivery for fund-level regulatory documents such as prospectuses and shareholder reports but may choose paper delivery for tax documents and/or trade confirmations). We understand that this category-specific approach is common for funds. We also understand that, for funds that do not already offer e-delivery on a document-by-document basis, building this capability would be extremely burdensome and would likely increase costs for funds and shareholders. Funds are best positioned to determine which options will best serve their shareholders and appropriately balance costs.
c. The Commission Should Permit Electronic-Only Products, Services, and Account Types.
The proposal does not discuss whether certain products, services or account types may be offered on an electronic-only basis. The SEC should acknowledge that firms may offer digital only products and services, wherein electronic delivery is an explicit condition of the product, service, or account type and is agreed to by the customer at the time of purchase.
F. Remediation of Failed Deliveries
ICI supports requiring covered entities to have written policies and procedures reasonably designed to identify and remediate failed e-delivery. We also generally agree that, if a covered entity identifies an e-delivery failure, it should promptly take remediation steps.43 We strongly support the Commission's statements that "the proposed remediation provisions are not intended to require covered entities to monitor account engagement, clickthrough rates, whether a message was opened, or reviewed" and that, "instead, the proposed requirements aim to address whether there was an actual failure to deliver."44
Funds are already subject to document delivery requirements, and many already have applicable policies and procedures. We request in any final rule that the Commission confirm and clarify that these existing policies and procedures, if consistent with the final requirements, would suffice.
The Commission should also confirm and clarify that covered entities have flexibility with respect to reasonable remediation approaches. Covered entities are best positioned to determine what constitutes a reasonable approach to monitoring for, and remediating, e-delivery failures, and a covered entity may take different reasonable approaches to addressing email "bounce-backs," mobile message delivery failures, and other e-delivery failures. Such approaches may not include immediately switching the shareholder to paper delivery and could, instead, include attempting to deliver to an alternate electronic address on file. If that and other reasonable alternatives also fail, it would be reasonable for a covered entity to temporarily suspend e-delivery for that recipient while the covered entity contacts the shareholder and obtains updated delivery instructions. We believe this is consistent with the Commission's views, which recognize that "[r]ather than immediately transitioning the covered recipient to paper delivery on a global basis . . ., the covered entity could send the covered information in paper while attempting to re-establish a valid or functional electronic address for future deliveries."45 We request that the Commission affirm this view and clarify that funds have broad flexibility to design their reasonable remediation policies and procedures.
G. Transition Process for Shareholders Who Have Provided Electronic Addresses But Currently Receive Paper
The proposal includes an e-delivery transition process for covered recipients who currently receive paper but who have provided an electronic address. A covered entity would provide such covered recipients two paper notices: the first at least 180 days prior to the transition and the second 30 days prior to the transition.
While we believe that there are many reasonable notice and transition frameworks, we generally support this proposed transition process, with the modifications discussed below. We also support an expansive definition of "covered recipient receiving paper," as proposed.46
a. The Commission Should Consider Shortening the Notice Timeline.
The proposed transition notice timeline (i.e., an initial notice at least 180 days prior, and a follow-up notice 30 days prior) is operationally feasible, and we appreciate that the Commission has proposed a timeline that is consistent with the recommendation in our November 2025 letter.
Upon further discussion with members, we recommend that the Commission consider shortening this period to require an initial notice at least 90 days prior to the transition47 and a follow-up notice approximately 30 days prior to the transition. We now believe that a shorter transition period--still with two notices--would better alert shareholders to the pending change and allow them to opt for paper. We also believe that, operationally, it may be challenging to deliver the follow-up notice precisely 30 days prior to the transition, and we request that the Commission affirm that covered entities need only provide the follow-up notice "approximately" (or "no later than" or some similarly flexible formulation) 30 days in advance.
Whether or not the Commission ultimately maintains the proposed timeline, we encourage the Commission to allow covered entities to send transition notices electronically to shareholders who are already receiving some covered information electronically, rather than on paper, and within a shorter notice timeline, such as 30 days total. These shareholders are already accustomed to receiving information electronically and therefore have some level of comfort with it. And in any event, they still may opt for paper.
b. Transition Notices Need Not Include the Covered Recipient's Full Electronic Address.
The initial and follow-up transition notices would include "the electronic address that will be used to deliver covered information to the covered recipient."48 This proposed requirement presents privacy and security concerns, and we strongly recommend that the Commission eliminate it. Instead, covered entities should be permitted to describe the electronic address to be used, such as "delivery to the email address on file" or "delivery to the mobile phone number previously provided." If the Commission moves forward with the proposed requirement, the Commission must permit covered entities to redact portions of the electronic address for security and privacy purposes.
c. The Commission Should Permit Transition Notices to be Delivered with Other Information.
The proposal would require that initial and follow-up transition notices be "provided separately from other communications."49 The Commission should permit transition notices to be delivered with other information. As discussed in Section III.D.b above, funds may wish to deliver these notices with other information, while still ensuring that the notices are clear and prominent. This would allow, for example, funds to deliver transition notices with a fund's shareholder report or annual prospectus update mailing, reducing the number of shareholder communications and overall delivery costs.
H. The Commission Should Permit "Householding" of Covered Information Under Regulation E-Delivery.
The Commission has previously recognized that householding50 provides greater convenience and cost savings for funds and investors by reducing duplicate document deliveries, 51 and we support the proposed amendments that would permit householding with respect to the electronic delivery of proxy materials.52 Duplicate deliveries to an electronic address could arise where multiple investors share an electronic address (e.g., spouses set up a shared email address for managing their financial affairs, or a parent establishes an account for a minor child) or an investor has multiple accounts with the same covered entity and with duplicate holdings. In these instances, duplicate delivery wastes resources and imposes unnecessary costs on fund shareholders.
Consistent with those proposed changes, we request that the Commission confirm, under Regulation E-Delivery, funds may household prospectuses and shareholder reports delivered to a shared electronic address to the same extent they may household comparable paper deliveries.53 This would be consistent with the Commission's longstanding views on householding. We see no reason to treat electronic delivery differently from paper delivery in this respect, and we request that the Commission explicitly permit householding broadly.
IV. E-Delivery Can Enhance Investor Protections.
In our November 2025 letter, we included enhanced investor protections as an e-delivery benefit. Some commenters have raised cybersecurity-related concerns in connection with the proposal, and we respond to those concerns here.
Although the potential for fraud exists everywhere in today's world, we continue to believe that e-delivery (compared to paper) is faster and more secure in many respects. As discussed in our November 2025 letter, the speed and direct nature of electronic communications, combined with the layers of security added by log-in requirements, provides greater privacy and security than paper mail.54 Fraud risk exists across delivery channels, and paper delivery presents its own vulnerabilities, including theft, mail fraud, mis-delivery, and delayed detection of unauthorized activity. By contrast, e-delivery can support stronger safeguards by enabling pre-authentication before sensitive information is accessed and keeping documents within a protected digital environment (unless a shareholder chooses to download or print them).
In addition, although the potential for an online account to be "hacked" exists, technology also exists to detect and combat this kind of activity. Funds may utilize a combination of security messages to alert investors of account access, as well as back-end surveillance reports designed to detect suspicious online activity patterns. Today, multifactor authentication is a common fund security protocol to safeguard investor credentials. No such protective measures exist once a paper document is mailed.
Commenters have also raised concerns about the potential for increased "phishing" activity and related shareholder confusion and susceptibility to phishing attempts if e-delivery becomes the default. These concerns are important and should be thoughtfully considered. As we discussed in our November 2025 letter, funds and advisers have invested significant resources into educating investors regarding the availability of online documents and effective habits for protecting themselves against fraud.55 Funds continuously update their websites, investor communications, and security protocols in support of evolving security safeguards and investor protection, including investor alerts focused on protecting personal information from mail or online fraud, or education tailored towards protecting older investors from the risks of elder fraud. We also note that covered entities will generally have standardized communication formats and predictable delivery timelines that may help recipients determine whether a communication is legitimate.
In our view, increased use of an "access equals delivery" framework would further mitigate these risks. Shareholders could proactively access covered materials from their bookmarked, trusted financial institutions' websites, at their convenience. For materials containing sensitive information, this access would occur only after self-authentication. This approach would meaningfully reduce phishing risk because shareholders would come to expect fewer "pushed" communications from covered entities. Unexpected emails containing links would therefore stand out as atypical, encouraging shareholders to access covered materials directly through trusted websites.
Similarly, generally reducing the volume of electronic communications (such as by combining e-deliveries of covered information with other materials, or by householding) would mitigate these risks. A lower volume of notices would allow shareholders to better identify and distinguish atypical notices. Lastly, allowing firms to brand, personalize, or otherwise distinguish their notices from generic communications may help shareholders better identify legitimate messages.
V. The NYSE Processing Fee Schedule is Flawed and Should Be Scrapped or Fundamentally Reformed.
While we commend the SEC for its work on e-delivery, we strongly reiterate our concerns about the current NYSE processing fee rules and our call for reform.56 The current NYSE processing fee framework has long been controversial.57 The SEC's Investor Advisory Committee raised concerns with the status quo in 201958 and again in June 2026 as part of its fund proxy reform recommendations.59
ICI has repeatedly objected to this framework as it applies to funds and has offered multiple reform recommendations.60 We again strongly urge the Commission to reform the current processing fee framework to further reduce the costs associated with delivering documents electronically to intermediary-held accounts. For the reasons discussed below, we believe that the current processing fee framework is anticompetitive and antithetical to the Commission's goals of encouraging e-delivery.
Under NYSE rules, NYSE member organizations (e.g., broker-dealers) must deliver disclosure materials to beneficial owners, including fund shareholders, that hold shares in nominee name through an intermediary. Funds must then reimburse NYSE member organizations for out-of-pocket, reasonable, clerical, postage, and other expenses, according to the NYSE fee schedule. While the NYSE fee schedule was originally intended to ensure a fair and reasonable allocation of costs, it has failed in practice. Intermediaries--which rely on third parties to meet this delivery obligation--have no incentive to negotiate lower rates with those third parties. The parties that pay the bills--funds--are cut out of this process and have little ability to lower these expenses for the benefit of their shareholders.
Furthermore, the NYSE fee schedule has historically included a "preference management fee" (or "suppression fee") which effectively charges a per-account fee to suppress paper mailings for shareholders who have opted into e-delivery. Because this fee is charged in perpetuity, it has consistently limited the cost savings that e-delivery provides to fund shareholders. In a speech earlier this year, Commissioner Peirce stated:
"The cost savings for investors from funds (or intermediaries) not having to print and mail so many documents would increase shareholders' return on their investment, which is why they invest in the first place. As a corollary, we may need to address the rather absurd situation in which a fund must pay intermediaries higher fees not to send paper documents to investors."61
We agree.
It is unclear how processing fees and, in particular, suppression fees, will change if Regulation E-Delivery is finalized and e-delivery becomes the default. If third-party vendors continue to charge suppression fees for e-delivery, fund and investor cost savings from e-delivery would be lower than they otherwise would be. The SEC itself estimates that the "cost of the preference management fee to investment companies relying on the proposed rule to [deliver] fund proxy voting materials, shareholder reports, and prospectuses, including summary prospectuses, to covered recipients would be $20 million per year."62 This is consistent with ICI's recent estimates between $11 and 25 million for total preference management fee costs for accounts being transitioned from paper delivery to e-delivery.63
Due to the nature of the proposal, however, the SEC did not estimate the cost of existing preference management fees on accounts that already receive e-delivery. ICI has previously estimated the total current preference management fees paid by funds and shareholders to range from approximately $119 to $151 million annually, and under the current framework, funds pay these fees in perpetuity.64 If the fee structure and general vendor practices stay the same after any final rule becomes effective, this figure would increase by the SEC's estimated $20 million for new e-delivery accounts.
We continue to believe that the NYSE fee framework is ill-suited to the distribution of fund materials and that the current process of reimbursing intermediaries for forwarding fund materials creates perverse incentives and inhibits market competition. Also, this proposal would allow shareholders to request paper delivery or paper copies of materials delivered electronically free of charge. We recognize that delivery of any kind--electronic or paper-- involves costs and that the reimbursement of pure out-of-pocket expenses associated with delivering fund materials is appropriate. Still, this proposal's spirit--and in some respects, its letter--is especially hard to square with the perpetual siphoning off as much as of $151 million annually of fund assets for merely recording shareholders' delivery preferences.
ICI has previously recommended that the Commission permit funds to negotiate with vendors and eliminate the need for a fee schedule by either:
* making clear that Section 14 rules under the Exchange Act65 permit funds to choose how to deliver fund regulatory materials and require intermediaries to provide to funds or their selected agent (i.e., vendor), upon request, a data file (i) with only the shareholder information necessary for delivering these materials (ii) to be used only for such purposes; or
* allowing funds to choose how to deliver fund regulatory materials by not applying the objecting beneficial owner (OBO)/non-objecting beneficial owner (NOBO) distinction for the purpose of distributing fund regulatory materials.66
As an alternative to the bullet directly above, funds could be permitted to choose their vendors, while requiring that information about OBOs that vendors gather remain with them alone, contractually "walled off" from the funds. This would allow funds to achieve cost savings from vendor selection while still preserving the current OBO/NOBO framework. Under this approach, funds would be incentivized to negotiate lower fulfillment costs, vendors chosen by funds would be incentivized to price competitively, and intermediaries would not have to administer the fulfillment of fund materials.
Permitting funds to negotiate the fees that they pay would improve competition and lower fees. If the Commission is unwilling to act on any of the above recommendations, ICI has also recommended that the SEC itself take control of and reform the fee schedule. But again, our preferred recommendations above would remove any entity--NYSE or SEC--from the rate setting process.
We also continue to strongly encourage the Commission to consider other measures that would decrease processing fees. For example, the Commission could permit "access equals delivery" (discussed further above) for some fund document types, which would avoid the imposition of processing fees on applicable documents altogether, as it would obviate the need for distributions. Absent actual processing fee reform, reducing the number of documents and notices delivered and subject to processing fees is the only way to realize more cost savings from e-delivery.
Again, we recognize the benefits of this proposal in its current form. And we understand the appeal of moving incrementally. Still, the Commission should not allow the current NYSE fee schedule and related practices--with all of their inequities and inefficiencies--to remain as the foundation for Regulation E-Delivery.
View full text of the letter here (https://www.ici.org/sites/default/files/2026-09/26-cl-sec-edelivery-modernization-proposal.pdf)
Florida Swimming Pool Association and Pool & Hot Tub Alliance Reunite Through Historic Affiliation
ALEXANDRIA, Virginia, Sept. 23 -- The Pool and Hot Tub Alliance (formerly the Association of Pool and Spa Professionals) issued the following news release:
* * *
September 22, 2026
Florida Swimming Pool Association and Pool & Hot Tub Alliance Reunite Through Historic Affiliation
Partnership takes effect January 1, 2027, bringing state and national organizations together to expand member value and strengthen the pool and hot tub industry
(Sarasota, Fl. / Alexandria, Va.) -- The Florida Swimming Pool Association (FSPA) and the Pool & Hot Tub Alliance (PHTA) today announced a new affiliation ... Show Full Article ALEXANDRIA, Virginia, Sept. 23 -- The Pool and Hot Tub Alliance (formerly the Association of Pool and Spa Professionals) issued the following news release: * * * September 22, 2026 Florida Swimming Pool Association and Pool & Hot Tub Alliance Reunite Through Historic Affiliation Partnership takes effect January 1, 2027, bringing state and national organizations together to expand member value and strengthen the pool and hot tub industry (Sarasota, Fl. / Alexandria, Va.) -- The Florida Swimming Pool Association (FSPA) and the Pool & Hot Tub Alliance (PHTA) today announced a new affiliationagreement, effective January 1, 2027, bringing together two leading organizations with a shared commitment to advancing the pool, spa, and hot tub industry.
The affiliation represents both a new chapter and a return to shared roots. FSPA operated as Region VII of the National Spa & Pool Institute (NSPI) during the 1960s and 1970s, transitioned to an independent affiliate in 2001, and became fully independent in 2008. Nearly two decades later, FSPA and PHTA are reuniting through a modern affiliation model designed to combine strong state and national resources while preserving FSPA's autonomy.
Under the affiliation, FSPA will continue to independently govern and operate its organization, while FSPA members will also gain membership in PHTA. The relationship brings together FSPA's deep Florida relationships, state advocacy, chapter network, and market expertise with PHTA's national education and certification programs, standards development, workforce initiatives, research, advocacy, and industry resources.
"FSPA has always been focused on delivering meaningful value to our members and strengthening the industry in Florida," says Keith Johnson, President of FSPA. "This affiliation allows us to maintain the identity, leadership, and local relationships that make FSPA strong while giving our members access to an even broader network of education, resources, and expertise. It is an exciting opportunity to bring our organizations back together in a way that positions our members and our industry for the future."
The organizations already have a strong history of collaboration, including FSPA's partnership with PHTA's Step Into Swim drowning prevention initiative, which has expanded significantly since 2020--funding more than 180,000 swim lessons in 2025 alone--while increasing support for community learn-to-swim programs.
"There is tremendous power in bringing the industry together while continuing to recognize the importance of strong state and local leadership," says Scott Frost, Chairman of the PHTA Board of Directors. "FSPA has an extraordinary history and presence in Florida, and PHTA brings national scale and resources that can complement that strength. Together, we can create greater opportunities for our members, speak with a stronger industry voice, and continue raising the level of professionalism throughout the industry."
The affiliation is designed to expand access to education and certification, strengthen workforce development, increase advocacy influence, enhance consumer safety initiatives, and provide members with additional resources and benefits. The FSPA-PHTA affiliation takes effect January 1, 2027.
For more information, please contact Amy Willer, PHTA's Senior Director of Content and Communications, at awiller@phta.org or 703-838-0083, ext. 121.
* * *
About the Florida Swimming Pool Association
The Florida Swimming Pool Association (FSPA) is a nonprofit trade association representing Florida's swimming pool, spa, and hot tub industry. For more than 50 years, FSPA has served as a trusted resource for pool builders, service professionals, manufacturers, and suppliers while promoting professionalism, education, and safety across the industry. Through advocacy, training, and consumer outreach, FSPA works to protect the interests of its members and advances best practices in pool and spa construction, maintenance, and design. FSPA also supports drowning prevention and water safety initiatives through its charitable arm, the Florida Swims Foundation, which provides funding for swim lessons and water safety education programs throughout the state. For more information, visit www.fspa.com.
* * *
About the Pool & Hot Tub Alliance
The Pool & Hot Tub Alliance (PHTA), a non-profit organization with 4,000 members from around the world, was established in 1956 to support, promote, and protect the common interests of the $62B pool, hot tub, and spa industry. PHTA provides education, advocacy, standards development, research, and market growth initiatives to increase our members' professionalism, knowledge, and profitability. Additionally, PHTA promotes the use of pools by expanding swimming, water safety, and related research and outreach activities aimed at introducing more people to swimming, making swimming environments safer, and keeping pools open to serve communities. For more information, visit www.phta.org.
* * *
URL: Florida Swimming Pool Association
* * *
Original text here: https://www.phta.org/news-research/press-releases/2026-press-releases/fspa-phta-reunite-through-historic-affiliation/
[Category: Business]
* * *
September 22, 2026
Florida Swimming Pool Association and Pool & Hot Tub Alliance Reunite Through Historic Affiliation
Partnership takes effect January 1, 2027, bringing state and national organizations together to expand member value and strengthen the pool and hot tub industry
(Sarasota, Fl. / Alexandria, Va.) -- The Florida Swimming Pool Association (FSPA) and the Pool & Hot Tub Alliance (PHTA) today announced a new affiliation ... Show Full Article ALEXANDRIA, Virginia, Sept. 23 -- The Pool and Hot Tub Alliance (formerly the Association of Pool and Spa Professionals) issued the following news release: * * * September 22, 2026 Florida Swimming Pool Association and Pool & Hot Tub Alliance Reunite Through Historic Affiliation Partnership takes effect January 1, 2027, bringing state and national organizations together to expand member value and strengthen the pool and hot tub industry (Sarasota, Fl. / Alexandria, Va.) -- The Florida Swimming Pool Association (FSPA) and the Pool & Hot Tub Alliance (PHTA) today announced a new affiliationagreement, effective January 1, 2027, bringing together two leading organizations with a shared commitment to advancing the pool, spa, and hot tub industry.
The affiliation represents both a new chapter and a return to shared roots. FSPA operated as Region VII of the National Spa & Pool Institute (NSPI) during the 1960s and 1970s, transitioned to an independent affiliate in 2001, and became fully independent in 2008. Nearly two decades later, FSPA and PHTA are reuniting through a modern affiliation model designed to combine strong state and national resources while preserving FSPA's autonomy.
Under the affiliation, FSPA will continue to independently govern and operate its organization, while FSPA members will also gain membership in PHTA. The relationship brings together FSPA's deep Florida relationships, state advocacy, chapter network, and market expertise with PHTA's national education and certification programs, standards development, workforce initiatives, research, advocacy, and industry resources.
"FSPA has always been focused on delivering meaningful value to our members and strengthening the industry in Florida," says Keith Johnson, President of FSPA. "This affiliation allows us to maintain the identity, leadership, and local relationships that make FSPA strong while giving our members access to an even broader network of education, resources, and expertise. It is an exciting opportunity to bring our organizations back together in a way that positions our members and our industry for the future."
The organizations already have a strong history of collaboration, including FSPA's partnership with PHTA's Step Into Swim drowning prevention initiative, which has expanded significantly since 2020--funding more than 180,000 swim lessons in 2025 alone--while increasing support for community learn-to-swim programs.
"There is tremendous power in bringing the industry together while continuing to recognize the importance of strong state and local leadership," says Scott Frost, Chairman of the PHTA Board of Directors. "FSPA has an extraordinary history and presence in Florida, and PHTA brings national scale and resources that can complement that strength. Together, we can create greater opportunities for our members, speak with a stronger industry voice, and continue raising the level of professionalism throughout the industry."
The affiliation is designed to expand access to education and certification, strengthen workforce development, increase advocacy influence, enhance consumer safety initiatives, and provide members with additional resources and benefits. The FSPA-PHTA affiliation takes effect January 1, 2027.
For more information, please contact Amy Willer, PHTA's Senior Director of Content and Communications, at awiller@phta.org or 703-838-0083, ext. 121.
* * *
About the Florida Swimming Pool Association
The Florida Swimming Pool Association (FSPA) is a nonprofit trade association representing Florida's swimming pool, spa, and hot tub industry. For more than 50 years, FSPA has served as a trusted resource for pool builders, service professionals, manufacturers, and suppliers while promoting professionalism, education, and safety across the industry. Through advocacy, training, and consumer outreach, FSPA works to protect the interests of its members and advances best practices in pool and spa construction, maintenance, and design. FSPA also supports drowning prevention and water safety initiatives through its charitable arm, the Florida Swims Foundation, which provides funding for swim lessons and water safety education programs throughout the state. For more information, visit www.fspa.com.
* * *
About the Pool & Hot Tub Alliance
The Pool & Hot Tub Alliance (PHTA), a non-profit organization with 4,000 members from around the world, was established in 1956 to support, promote, and protect the common interests of the $62B pool, hot tub, and spa industry. PHTA provides education, advocacy, standards development, research, and market growth initiatives to increase our members' professionalism, knowledge, and profitability. Additionally, PHTA promotes the use of pools by expanding swimming, water safety, and related research and outreach activities aimed at introducing more people to swimming, making swimming environments safer, and keeping pools open to serve communities. For more information, visit www.phta.org.
* * *
URL: Florida Swimming Pool Association
* * *
Original text here: https://www.phta.org/news-research/press-releases/2026-press-releases/fspa-phta-reunite-through-historic-affiliation/
[Category: Business]
ERIC Files Amicus Brief Urging Ninth Circuit to Uphold Dismissal of Forfeiture Suit Against AT&T
WASHINGTON, Sept. 23 -- The ERISA Industry Committee issued the following news release:
* * *
ERIC Files Amicus Brief Urging Ninth Circuit to Uphold Dismissal of Forfeiture Suit Against AT&T
September 22, 2026
Washington - The ERISA Industry Committee (ERIC) and coalition partners filed an amicus brief with the U.S. Court of Appeals for the Ninth Circuit, supporting AT&T in Hernandez v. AT&T Services, Inc. The brief urges the court to affirm a district court ruling that AT&T did nothing wrong by using forfeited 401(k) contributions to offset the company's future contributions to the plan.
When ... Show Full Article WASHINGTON, Sept. 23 -- The ERISA Industry Committee issued the following news release: * * * ERIC Files Amicus Brief Urging Ninth Circuit to Uphold Dismissal of Forfeiture Suit Against AT&T September 22, 2026 Washington - The ERISA Industry Committee (ERIC) and coalition partners filed an amicus brief with the U.S. Court of Appeals for the Ninth Circuit, supporting AT&T in Hernandez v. AT&T Services, Inc. The brief urges the court to affirm a district court ruling that AT&T did nothing wrong by using forfeited 401(k) contributions to offset the company's future contributions to the plan. Whena worker leaves before fully earning an employer's 401(k) contributions, the unvested portion is left in the plan. Federal law bars returning that money to the employer but has long let administrators use it for upcoming contributions, plan expenses, or restoration if the employee returns.
The former employee's attorneys argued AT&T should have used the funds for administrative expenses instead of future contributions, though nothing in the plan, ERISA, or regulations requires that. A federal district court in California dismissed the case in full, without leave to amend, finding the theory contrary to ERISA and settled law, as other courts have held in numerous nearly identical suits.
"Retirement plans work because employers can rely on the rules they wrote into them and what the regulators say is permissible," said Doug Hinson, Executive Director of the ERIC Legal Center. "AT&T's plan spells out exactly how forfeited funds can be used, and the company followed those terms. Plaintiffs want the court to rewrite that bargain after the fact, using a new theory that's inconsistent with what every administration for decades and courts nationwide have allowed. This case, and the many others like it, are totally wrong about what the law requires regarding forfeited contributions. The district court got it right. So should the appellate court."
Read the brief here (https://us.list-manage.com/kzHO6eUJPmQ?e=4b9822ddff&c2id=b42d6fb3a747b5f9a74f8375e11f372e).
* * *
About The ERISA Industry Committee
ERIC is a national advocacy organization that exclusively represents large employers that provide health, retirement, paid leave, and other benefits to their nationwide workforces. With member companies that are leaders in every sector of the economy, ERIC advocates on the federal, state, and local levels for policies that promote flexibility and uniformity in the administration of their employee benefit plans.
* * *
Original text here: https://www.eric.org/press_release/eric-files-amicus-brief-urging-ninth-circuit-to-uphold-dismissal-of-forfeiture-suit-against-att/
[Category: Human Resources/Personnel]
* * *
ERIC Files Amicus Brief Urging Ninth Circuit to Uphold Dismissal of Forfeiture Suit Against AT&T
September 22, 2026
Washington - The ERISA Industry Committee (ERIC) and coalition partners filed an amicus brief with the U.S. Court of Appeals for the Ninth Circuit, supporting AT&T in Hernandez v. AT&T Services, Inc. The brief urges the court to affirm a district court ruling that AT&T did nothing wrong by using forfeited 401(k) contributions to offset the company's future contributions to the plan.
When ... Show Full Article WASHINGTON, Sept. 23 -- The ERISA Industry Committee issued the following news release: * * * ERIC Files Amicus Brief Urging Ninth Circuit to Uphold Dismissal of Forfeiture Suit Against AT&T September 22, 2026 Washington - The ERISA Industry Committee (ERIC) and coalition partners filed an amicus brief with the U.S. Court of Appeals for the Ninth Circuit, supporting AT&T in Hernandez v. AT&T Services, Inc. The brief urges the court to affirm a district court ruling that AT&T did nothing wrong by using forfeited 401(k) contributions to offset the company's future contributions to the plan. Whena worker leaves before fully earning an employer's 401(k) contributions, the unvested portion is left in the plan. Federal law bars returning that money to the employer but has long let administrators use it for upcoming contributions, plan expenses, or restoration if the employee returns.
The former employee's attorneys argued AT&T should have used the funds for administrative expenses instead of future contributions, though nothing in the plan, ERISA, or regulations requires that. A federal district court in California dismissed the case in full, without leave to amend, finding the theory contrary to ERISA and settled law, as other courts have held in numerous nearly identical suits.
"Retirement plans work because employers can rely on the rules they wrote into them and what the regulators say is permissible," said Doug Hinson, Executive Director of the ERIC Legal Center. "AT&T's plan spells out exactly how forfeited funds can be used, and the company followed those terms. Plaintiffs want the court to rewrite that bargain after the fact, using a new theory that's inconsistent with what every administration for decades and courts nationwide have allowed. This case, and the many others like it, are totally wrong about what the law requires regarding forfeited contributions. The district court got it right. So should the appellate court."
Read the brief here (https://us.list-manage.com/kzHO6eUJPmQ?e=4b9822ddff&c2id=b42d6fb3a747b5f9a74f8375e11f372e).
* * *
About The ERISA Industry Committee
ERIC is a national advocacy organization that exclusively represents large employers that provide health, retirement, paid leave, and other benefits to their nationwide workforces. With member companies that are leaders in every sector of the economy, ERIC advocates on the federal, state, and local levels for policies that promote flexibility and uniformity in the administration of their employee benefit plans.
* * *
Original text here: https://www.eric.org/press_release/eric-files-amicus-brief-urging-ninth-circuit-to-uphold-dismissal-of-forfeiture-suit-against-att/
[Category: Human Resources/Personnel]
American Chemistry Council: 100+ Organizations Outline Principles for Risk Management
WASHINGTON, Sept. 23 -- The American Chemistry Council posted the following news release:
* * *
100+ Organizations Outline Principles for Risk Management
Coalition calls for transparent, targeted and practical regulations
WASHINGTON (September 22, 2026) -- The American Chemistry Council (ACC) along with the American Alliance for Innovation (AAI) - a coalition of more than 100 organizations -- provided a set of management principles to Doug Troutman, Assistant Administrator for the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention. The coalition ... Show Full Article WASHINGTON, Sept. 23 -- The American Chemistry Council posted the following news release: * * * 100+ Organizations Outline Principles for Risk Management Coalition calls for transparent, targeted and practical regulations WASHINGTON (September 22, 2026) -- The American Chemistry Council (ACC) along with the American Alliance for Innovation (AAI) - a coalition of more than 100 organizations -- provided a set of management principles to Doug Troutman, Assistant Administrator for the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention. The coalitionencouraged the EPA to consider the principles as a foundation as it develops future regulations under the Toxic Substances Control Act (TSCA).
AAI members rely on chemicals and chemical-based products to support advanced manufacturing, infrastructure, energy, healthcare and other essential sectors. The principles were developed to provide the coalition with a common framework for evaluating and engaging in TSCA risk management measures and to support approaches that are transparent, predictable, science-based and appropriately tailored to identified unreasonable risks.
"Chemistry is foundational to American manufacturing, innovation, healthcare, energy and countless products that people rely on every day." said Dr. Kimberly Wise White, ACC Vice President of Regulatory and Scientific Affairs. "The principles provide a practical framework for risk management that is science-based, tailored to identified risks and capable of being implemented effectively. By promoting transparency, predictability and sound decision-making, these principles can help EPA develop regulations that protect health and the environment while preserving the benefits that chemistry delivers to society.
The coalition's five principles call on EPA to:
* Apply a transparent and consistent framework;
* Regulate only to the extent necessary;
* Base decisions on the weight of the evidence and best available science;
* Develop targeted, flexible and tailored measures; and
* Avoid regulatory overlap and achieve balanced outcomes.
Together, these principles would help EPA develop more effective and predictable regulations while supporting innovation, U.S. competitiveness, resilient supply chains and regulatory certainty.
View and download the coalition letter and risk management principles here.
For more information about TSCA implementation, visit ACC's TSCA webpage.
* * *
American Chemistry Council
The American Chemistry Council's mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care(R); Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably--for generations to come.
* * *
Original text here: https://www.americanchemistry.com/chemistry-in-america-industry-innovation-impact/news-trends/press-release/2026/100-organizations-outline-principles-for-risk-management
[Category: Chemicals]
* * *
100+ Organizations Outline Principles for Risk Management
Coalition calls for transparent, targeted and practical regulations
WASHINGTON (September 22, 2026) -- The American Chemistry Council (ACC) along with the American Alliance for Innovation (AAI) - a coalition of more than 100 organizations -- provided a set of management principles to Doug Troutman, Assistant Administrator for the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention. The coalition ... Show Full Article WASHINGTON, Sept. 23 -- The American Chemistry Council posted the following news release: * * * 100+ Organizations Outline Principles for Risk Management Coalition calls for transparent, targeted and practical regulations WASHINGTON (September 22, 2026) -- The American Chemistry Council (ACC) along with the American Alliance for Innovation (AAI) - a coalition of more than 100 organizations -- provided a set of management principles to Doug Troutman, Assistant Administrator for the U.S. Environmental Protection Agency's (EPA) Office of Chemical Safety and Pollution Prevention. The coalitionencouraged the EPA to consider the principles as a foundation as it develops future regulations under the Toxic Substances Control Act (TSCA).
AAI members rely on chemicals and chemical-based products to support advanced manufacturing, infrastructure, energy, healthcare and other essential sectors. The principles were developed to provide the coalition with a common framework for evaluating and engaging in TSCA risk management measures and to support approaches that are transparent, predictable, science-based and appropriately tailored to identified unreasonable risks.
"Chemistry is foundational to American manufacturing, innovation, healthcare, energy and countless products that people rely on every day." said Dr. Kimberly Wise White, ACC Vice President of Regulatory and Scientific Affairs. "The principles provide a practical framework for risk management that is science-based, tailored to identified risks and capable of being implemented effectively. By promoting transparency, predictability and sound decision-making, these principles can help EPA develop regulations that protect health and the environment while preserving the benefits that chemistry delivers to society.
The coalition's five principles call on EPA to:
* Apply a transparent and consistent framework;
* Regulate only to the extent necessary;
* Base decisions on the weight of the evidence and best available science;
* Develop targeted, flexible and tailored measures; and
* Avoid regulatory overlap and achieve balanced outcomes.
Together, these principles would help EPA develop more effective and predictable regulations while supporting innovation, U.S. competitiveness, resilient supply chains and regulatory certainty.
View and download the coalition letter and risk management principles here.
For more information about TSCA implementation, visit ACC's TSCA webpage.
* * *
American Chemistry Council
The American Chemistry Council's mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care(R); Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably--for generations to come.
* * *
Original text here: https://www.americanchemistry.com/chemistry-in-america-industry-innovation-impact/news-trends/press-release/2026/100-organizations-outline-principles-for-risk-management
[Category: Chemicals]
API Statement on Potential U.S. Diesel Export Ban
WASHINGTON, Sept. 23 -- The American Petroleum Institute posted the following news release:
* * *
API Statement on Potential U.S. Diesel Export Ban
WASHINGTON, September 22, 2026 - The American Petroleum Institute (API) today released the following statement from President and CEO Mike Sommers on news that the administration is considering restrictions on U.S. diesel exports.
"Americans are hurting from rising diesel costs driven by an unprecedented disruption to global refining capacity. We understand the administration is looking at every option to deliver relief, but restricting U.S. energy ... Show Full Article WASHINGTON, Sept. 23 -- The American Petroleum Institute posted the following news release: * * * API Statement on Potential U.S. Diesel Export Ban WASHINGTON, September 22, 2026 - The American Petroleum Institute (API) today released the following statement from President and CEO Mike Sommers on news that the administration is considering restrictions on U.S. diesel exports. "Americans are hurting from rising diesel costs driven by an unprecedented disruption to global refining capacity. We understand the administration is looking at every option to deliver relief, but restricting U.S. energyexports would only compound the problem--exacerbating refining challenges and ultimately hurting consumers. The answer is more supply and more flexibility--not new restrictions that risk making a difficult situation worse."
* * *
BACKGROUND
Restricting U.S. diesel exports would wreak havoc on fuel markets at home and abroad, destabilize refinery operations and deepen a global refining crisis already putting upward pressure on U.S. prices. Gulf Coast refineries produce more diesel than the region consumes, while geography and infrastructure constraints prevent that surplus from simply being redirected to every U.S. market that needs it. Exports provide an essential outlet that allows those refineries to keep running at high rates. Limiting access to global markets could force refiners to cut runs--reducing production of diesel, gasoline and jet fuel and tightening supplies further at home and abroad.
* * *
The American Petroleum Institute (API) represents all segments of America's oil and natural gas industry, supporting nearly 11 million U.S. jobs. With approximately 600 members, API companies produce, process, and distribute the majority of the nation's energy. Founded in 1919, API has developed over 800 standards to enhance operational and environmental safety, efficiency, and sustainability.
* * *
Original text here: https://www.api.org/news-policy-and-issues/news/2026/09/22/api-statement-on-potential-us-diesel-export-ban
[Category: Energy]
* * *
API Statement on Potential U.S. Diesel Export Ban
WASHINGTON, September 22, 2026 - The American Petroleum Institute (API) today released the following statement from President and CEO Mike Sommers on news that the administration is considering restrictions on U.S. diesel exports.
"Americans are hurting from rising diesel costs driven by an unprecedented disruption to global refining capacity. We understand the administration is looking at every option to deliver relief, but restricting U.S. energy ... Show Full Article WASHINGTON, Sept. 23 -- The American Petroleum Institute posted the following news release: * * * API Statement on Potential U.S. Diesel Export Ban WASHINGTON, September 22, 2026 - The American Petroleum Institute (API) today released the following statement from President and CEO Mike Sommers on news that the administration is considering restrictions on U.S. diesel exports. "Americans are hurting from rising diesel costs driven by an unprecedented disruption to global refining capacity. We understand the administration is looking at every option to deliver relief, but restricting U.S. energyexports would only compound the problem--exacerbating refining challenges and ultimately hurting consumers. The answer is more supply and more flexibility--not new restrictions that risk making a difficult situation worse."
* * *
BACKGROUND
Restricting U.S. diesel exports would wreak havoc on fuel markets at home and abroad, destabilize refinery operations and deepen a global refining crisis already putting upward pressure on U.S. prices. Gulf Coast refineries produce more diesel than the region consumes, while geography and infrastructure constraints prevent that surplus from simply being redirected to every U.S. market that needs it. Exports provide an essential outlet that allows those refineries to keep running at high rates. Limiting access to global markets could force refiners to cut runs--reducing production of diesel, gasoline and jet fuel and tightening supplies further at home and abroad.
* * *
The American Petroleum Institute (API) represents all segments of America's oil and natural gas industry, supporting nearly 11 million U.S. jobs. With approximately 600 members, API companies produce, process, and distribute the majority of the nation's energy. Founded in 1919, API has developed over 800 standards to enhance operational and environmental safety, efficiency, and sustainability.
* * *
Original text here: https://www.api.org/news-policy-and-issues/news/2026/09/22/api-statement-on-potential-us-diesel-export-ban
[Category: Energy]