Thank you, Chairman Schapiro.
I support the recommendation to amend Part 2 of Form ADV and want to speak to just one topic. As the release explains, the Commission received a number of comments on the means by which an adviser is permitted to deliver its updated brochure to investors annually. Under the Form, electronic delivery is to be in accordance with the Commission's 1996 electronic delivery guidelines.
Commenters recommended that the Commission afford advisers more leeway in satisfying the annual brochure delivery requirement. Consistent with the tenor of these comments, I encourage the staff to continue considering different means for the delivery of information to investors.
Much has changed over the 14 years since the 1996 electronic delivery guidelines were adopted. Today, for example, investors have widespread access to the Internet, with the ability to connect using an expanding array of devices, not just traditional computers. Methods for sending and receiving email have become much more standardized, and important information is routinely accessed from websites, as parties look to capture the efficiencies that technology permits. Indeed, many diverse commercial interactions occur online as a routine matter. These and similar developments argue in favor of updating the 1996 guidelines.
As always, I join my colleagues in thanking the many members of the staff — particularly those from the Division of Investment Management — who have contributed to this rulemaking. I appreciate your efforts.
