The SEC’s new proposed E-Delivery Rule seeks to modernize the process of firms providing required disclosures, reports and other regulatory information. Once finalized, the rule would allow firms to use e-delivery without obtaining affirmative consent from clients. FrontLine Compliance Founder and President Amy Lynch extensively discusses the significance of the rule for compliance departments. She comments that it would allow for more accurate tracking of information delivery since electronic tracking is much more efficient than paper tracking while also greatly reducing costs. Ms. Lynch further highlights that the SEC considered personally identifiable information (PII) within the rule requirements by providing guidance on how documents with PII are to be delivered, compared to those without PII, to protect clients from fraud. She adds that the new rule would also require updating IMAs and websites regarding their disclosures for electronic delivery of documents and communications, in addition to ensuring email addresses are obtained for each client. Importantly, Ms. Lynch stresses that firms will need to have proof of e-delivery or lack thereof, and the systems utilized would need built-in tracking, such as what sophisticated data rooms now encompass. See ThinkAdvisor (free registration), “SEC Releases New E-Delivery Rule”
Amy Lynch explains E-Delivery Rule’s impact on compliance (ThinkAdvisor)
FrontLine Compliance