ICI to SEC: E-Delivery Can Save Investors Billions
Washington, DC; November 19, 2025—The Investment Company Institute (ICI) submitted a letter to the Securities and Exchange Commission (SEC) outlining significant cost-savings estimates to support rulemaking that would allow funds to deliver documents to shareholders electronically on a default basis (e-delivery).
The new estimates ICI shared with the SEC show potential annual savings ranging from $589 million to $797 million per year for funds and their shareholders, with projected cumulative savings of $3 billion to $4 billion over five years from transitioning to e-delivery. ICI data also found that fund investors overwhelmingly prefer to receive electronic delivery and support e-delivery with 88% of fund investors agreeing that “as long as people can still request paper at no cost, it’s a good idea to make e-delivery the default.”
“ICI’s data finds that — even using conservative estimates — American middle-class investors would save several billion dollars by switching to default e-delivery,” said ICI President and CEO Eric Pan. “Not only is e-delivery cost efficient, investors want it. Our survey shows a vast majority of Americans support an e-delivery default. The SEC should follow the cost data and listen to investors to make e-delivery a reality.”
Key points from ICI’s letter:
- In addition to the cost savings noted above, a broad, industry-wide transition could save investors staggering amounts of money—much more than the $3 billion to $4 billion in savings over five years that ICI has estimated for funds alone.
- ICI recommends that the permitted means of electronic delivery should be flexible, technology neutral, and evergreen.
- Investors must have the ability to elect paper delivery, or change their delivery elections, at any time.
- Funds delivering electronic documents should not be held to a higher standard than funds delivering paper documents. Once a fund sends an electronic document or notification, the fund’s delivery obligation should be satisfied, consistent with standards for paper delivery.
Read ICI’s full letter to the SEC here.