ICI President Eric J. Pan praised the SEC initiative as a vital modernization, noting that the vast majority of American investors already navigate their financial lives online. The organization estimates that transitioning to an electronic-first framework could save shareholders between $3 billion and $4 billion over the next five years by slashing mailing expenses and reducing paper waste. Under the proposed rules, investors would retain the right to opt back into paper delivery at no additional cost.

To ensure the final rule remains durable, the ICI suggested several technical adjustments. These include implementing an "access equals delivery" standard for routine reports and refining how firms handle failed electronic transmissions. The group also called for a broader overhaul of existing processing fee structures, arguing that current costs unfairly inflate the burden on funds. According to an ICI survey, 88% of investors support making digital delivery the default, provided the option for physical documents remains available for those who prefer them.