https://www.sec.gov/comments/S7-2026-25/s7202625-997759-3143107.pdf
August 10, 2026
Via electronic submission (rule-comments@sec.gov)
Ms. Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Re: File No. S7-2026-25; Release Nos. 33-11430, 34-105921 — Electronic Delivery of Information Under the Federal Securities Laws (Proposed Regulation E-Delivery) — Comment in Support
Dear Ms. Countryman:
I submit this letter in strong support of proposed Regulation E-Delivery. Making electronic delivery the default for disclosure under the Federal securities laws, while preserving every investor’s right to paper on request and at no cost, is the most sensible disclosure reform the Commission has proposed in years. I urge the Commission to adopt it, and to go further in the directions described below.
Who I am and why I hold this view
I am Andy Altahawi, founder and Chief Executive Officer of Adamson Brothers, and the principal of Directly Listed, an advisory practice for companies pursuing initial public offerings, direct listings, and uplistings on NYSE and NASDAQ. Adamson Brothers Inc. was a full-service U.S. broker-dealer and investment banking firm registered with FINRA under CRD #46684, and for many years the firm operated as a NASDAQ market maker, alongside equity and bond trading, options, mutual funds, and a corporate finance practice that took hundreds of companies public on U.S. exchanges and the OTC markets. Throughout its broker-dealer years, neither the firm nor I was ever the subject of a customer complaint or a regulatory citation from FINRA, the SEC, or the NASD.
Before founding Adamson Brothers in 1998, I served as Senior Vice President in the Investment Banking division of Prudential Securities (1994–1998), then led by Wick Simons, the former Chairman of NASDAQ. I have held FINRA registrations since 1994, including the Series 55 equity trader, Series 24 general securities principal, Series 4 registered options principal, and Series 79 investment banking qualifications, together with the Series 3, 6, 7, 63, and 65 examinations. I have also practiced law internationally since 1988, concentrating on cross-border corporate structuring, commercial arbitration, and governance counsel to boards of publicly traded companies, and I hold a Ph.D. in Finance. Additional background on my securities and legal work is available at andyaltahawi.com and andyaltahawiSEC.com.
I ran the mailrooms this rule would retire
This proposal is not abstract to me. As a NASDAQ market maker and the principal of a multi-office broker-dealer, my firm lived under the paper delivery regime: printed prospectuses shipped to customers on offering after offering, trade confirmations in envelopes, proxy packages and annual reports by the carton, and postage bills that ran with the size of our customer book. When Adamson Brothers took companies public, part of every deal budget went to printing and mailing documents that most recipients never opened, and every compliance calendar was built around mail float, the days a disclosure spends in transit while the market keeps moving. The customer would often execute, settle, and see the position on screen before the paper arrived to tell them what they had bought. Those costs did not protect anyone. They were charged, ultimately, to issuers and to investors, for a delivery method whose main output was landfill. The Commission’s 2000 guidance let firms escape that regime only through an opt-in consent process so cumbersome that a quarter century later, paper is still the legal default. Regulation E-Delivery finally corrects the default to match how investors actually live.
The paper default is an artifact; the investor has already moved
Today’s investor opens the account electronically, signs electronically, funds electronically, trades from a phone, and checks the position on a screen, and then the securities laws presume that this same person can only be informed by an envelope. Nothing in that presumption reflects a policy judgment; it is a leftover from the world I started in, when the printed document was the only way information could travel. Every other layer of the market has already crossed over. EDGAR made filings electronic decades ago. Clearing runs at T+1. The Commission itself accepts comments, like this one, through a web form. The delivery default is the last analog holdout in an otherwise digital market, and the proposal’s own design concedes how one-sided the case is: the substantial majority of investors who currently receive paper are expected simply to stay with electronic delivery once the friction of affirmative consent is removed, because it is what they already wanted.
In the age of AI, electronic disclosure is better disclosure — not merely cheaper
The strongest argument for Regulation E-Delivery is not the printing and postage savings, real as they are. It is that a disclosure delivered electronically is the only disclosure a modern investor can actually use. An electronic document is searchable; a 300-page prospectus on paper is not. An electronic document can be enlarged for aging eyes, read aloud by accessibility software, translated for an investor whose first language is not English, and compared instantly against last quarter’s version. And in the age of AI, an electronic disclosure can be interrogated: an ordinary retail investor can now ask intelligent software to summarize a registration statement, flag the risk factors that changed, or explain a fee table in plain language, which is more analytical power than a professional analyst had when I started at Prudential. Every one of those capabilities requires the document to arrive as data rather than as ink. Paper delivery does not merely cost more; it strands the investor at the exact moment technology has made disclosure genuinely useful to non-professionals for the first time. The crypto era, whatever else one thinks of it, settled the cultural question: an entire generation now assumes that anything that matters about their money is available on their device, instantly. That expectation belongs to the regulated securities market too. The past mailed documents; the future delivers information.
The early objections deserve a real answer, and the proposal already contains one
I have read the initial comments on this file, several of which worry about investors who prefer paper or lack reliable internet access. The concern is legitimate and the proposal already answers it: no one loses paper. Any investor may opt out at the start, opt out later, or request any individual document in paper, free of charge, forever. Current paper recipients get at least 180 days’ notice plus a 30-day reminder before anything changes. That is not the elimination of choice; it is the correction of a default that today forces the digital majority through an opt-in maze in order to protect a paper minority who will keep every right they have. The Commission should hold that line in adoption: a one-step, plain-English opt-out, honored promptly and permanently, is the covenant that makes the new default fair.
The issuer’s seat: paper delivery is a tax on capital formation
Through Directly Listed and Adamson Brothers, I advise issuers, many of them foreign private issuers, preparing for U.S. listings, and the paper regime shows up in every budget as a pure deadweight cost: printing and mailing to global shareholder bases, cross-border postage that can exceed the cost of the document itself, and fund and issuer expenses that are ultimately deducted from investor returns. For a foreign issuer weighing a U.S. listing, these obligations read as exactly what they are, a legacy requirement no modern market should still impose. Regulation E-Delivery removes a real, recurring cost of being a U.S. public company at the moment the Commission is working to make public markets attractive again. It also aligns the delivery rules with the direct listing and IPO processes I work on, which are already electronic end to end in every respect except this one.
Recommendations for adoption
To make a strong proposal stronger, the Commission should:
1. adopt the opt-out default as proposed, including the E-SIGN accommodation, and resist any carve-outs that would recreate the affirmative-consent maze document by document;
2. require that a failed electronic delivery, such as a hard email bounce, trigger prompt fallback to paper and a cure process, so no investor silently loses disclosure;
3. keep the opt-out one step, free, permanent until changed, and honored across affiliated entities, with plain-English transition notices;
4. pair e-delivery with machine-readable formatting requirements, so delivered documents are structured data that investors, and the AI tools they increasingly rely on, can search, compare, and summarize; and
5. treat this rule as the bridge to a considered "access equals delivery" framework for EDGAR-filed documents, on which the Commission has rightly requested comment.
Conclusion
I spent years paying to print and mail documents that technology now delivers instantly, searchably, and at almost no cost. The paper default served the market I joined in the 1990s; it does not serve the market we have. Regulation E-Delivery modernizes the delivery mechanism while leaving every investor’s substantive rights, and the paper option itself, fully intact. That is what good modernization looks like: adding capability without subtracting protection. I urge the Commission to adopt the rule promptly, and I would be pleased to assist the staff with the perspectives of broker-dealers, foreign issuers, and international investors.
Thank you for the opportunity to comment.
Respectfully submitted,
/s/ Andy Altahawi
Founder and Chief Executive Officer
Adamson Brothers Corp. (former FINRA-registered broker-dealer and NASDAQ market maker, CRD #46684)
This post is provided for informational purposes only and is not investment advice or a solicitation. See our Disclaimer, Terms of Use, and Privacy Policy.