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AF&PA Statement on SEC Regulation E-Delivery Proposal

Proposal would sideline paper communications millions rely on for critical financial information

WASHINGTON – American Forest & Paper Association (AF&PA) Interim Vice President of Industry Affairs Mark Pitts released the following statement in response to the Securities and Exchange Commission’s (SEC) proposed Regulation E-Delivery, a consequential rulemaking that would make electronic delivery the default method for many investor communications and significantly reduce the role of paper in delivering important financial information.

AF&PA is deeply concerned by today’s proposal, which would represent a major shift away from paper as the default for critical financial disclosures that millions of Americans rely on to make informed decisions. 

"For many investors—particularly seniors, rural communities and individuals with limited or unreliable digital access—paper is not a preference; it is an essential, trusted and secure way to receive and retain important information.

“This proposal also raises serious concerns for the U.S. printing and writing paper sector, which supports U.S. manufacturing jobs and provides essential products for consumers, businesses and institutions across the country.

“Investor choice cannot become an afterthought in the name of modernization. Investors already have the option to choose digital delivery if that is their preference. AF&PA will remain engaged to protect investor choice, maintain meaningful access to paper and ensure the final rule recognizes the continued value and necessity of printed communications.”

The American Forest & Paper Association (AF&PA) serves to advance public policies that foster economic growth, job creation and global competitiveness for a vital sector that makes the essential paper and packaging products Americans use every day. The U.S. forest products industry employs more than 925,000 people, largely in rural America, and is among the top 10 manufacturing sector employers in 44 states. Our industry accounts for approximately 4.7% of the total U.S. manufacturing GDP, manufacturing more than $435 billion in products annually. AF&PA member companies are significant producers and users of renewable biomass energy and are committed to making sustainable products for a sustainable future through the industry’s decades-long initiative — Better Practices, Better Planet 2030