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Coalition for Paper Options Files Comments Calling on the Dept. of Labor to Reject Proposed Rule Shifting All Workers to Paperless Retirement Disclosures

The Consumer Advocate & Paper Industry Alliance Says Rule Lacks Sufficient Review Process & Ignores

Long-Held Standards for New Regulation

WASHINGTON, D.C. (November 21, 2019) – The Coalition for Paper Options – an alliance of consumer organizations, labor unions, rural advocates, and print communications industry organizations – today filed comments calling on the U.S. Department of Labor (DOL) to reject a new proposed rule that would allow retirement plan fiduciaries to switch the current default delivery method for important retirement plan disclosures from paper to electronic.


In comments to Eugene Scalia, secretary of the Department of Labor, the Coalition for Paper Options called on the agency to postpone consideration of the proposed rule and proceed with conducting evidence-based research on several outstanding questions, as outlined in the Coalition’s comments. The proposed rule, announced on October 23, 2019, would allow retirement plan disclosures to be posted online, primarily to save money for plan fiduciaries.


The Coalition for Paper Options argues that the proposed rule ignores the spirit and intent of Executive Order 13847, which charged the DOL with completing “a review of make retirement disclosures…more understandable and useful for participants,” and “an exploration of the broader use of e-delivery as a way to improve effectiveness.”


“Instead of carefully considering how to make the disclosures more useful for participants, we believe DOL overlooked this part of the order and went straight to a proposed rule to mandate e-delivery as the default method of delivery for these critical documents,” the Coalition writes.


The Coalition continued, “survey research on this topic would have revealed a difference between access to the internet and a very strong participant preference for paper-based information when it comes to important financial information,” citing similar FINRA and SEC research revealing a strong preference for paper on the part of individual investors.


The Coalition for Paper Options also notes that federal government experience with e-delivery mandates demonstrates flaws.


“DOL also cites as evidence for how well e-delivery can work, two examples that clearly illustrate the flaws with this approach that will harm wage earners and retail investors,” writes the Coalition for Paper Options, pointing to online access of Social Security benefit statements and the proxy voting process for investments regulated by the SEC as “but two examples showing steep declines in readership and participation following conversion to online distribution.”


The DOL admits it doesn’t have adequate data for key populations – a grave oversight, according to the Coalition for Paper Options. 


The Coalition writes, “this research should have been done prior to the issuance of the proposed rule and that the rule should not move forward until such research is completed. Efforts to mitigate adverse impacts should be mandatory, not voluntary.”


In its comments, the Coalition for Paper Options highlights several additional pitfalls of the proposed rule, including insufficient justification of a “market failure,” required by the longstanding regulatory principle in Executive Order 12866, an inadequate comment period, and more.


To read the comments in full, click here.


About the Coalition for Paper Options

The Coalition for Paper Options is an alliance of consumer organizations, labor unions, rural advocates, and print communications industry organizations and employees who recognize the need to preserve access to important paper-based information and services for Americans who prefer them or depend on them. While the Coalition for Paper Options supports the use of technology, we believe that the government and private sector should promote digital services and information without discriminating against citizens who want or need more traditional access. By giving Americans a choice, we can bridge the digital divide and save millions of dollars – without shifting cost burdens to citizens who can least afford them. For more information and a list of members, visit


John Runyan

Executive Director 

8 E St. SE

Washington, DC 20003 


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