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Consumer Advocates & Paper Industry Ask Trump Administration to Reject Dept. of Labor Regulation Shifting All Workers to Paperless Retirement Disclosures

Coalition for Paper Options, Including Members National Grange & Consumer Action, Say Dept. of Labor’s Draft Rule is ‘Unjustified’ for Failing to Meet Long-Held Standards for New Regulation

WASHINGTON, D.C. (October 8, 2019) – The Coalition for Paper Options – an alliance of consumer organizations, labor unions, rural advocates, and print communications industry organizations – today called on the Trump Administration to reject a proposed rule by the Department of Labor allowing retirement plan fiduciaries to switch the current default delivery method for important retirement plan disclosures from paper to electronic. Amidst the administration’s push to deregulate industry, the Coalition for Paper Options argues that the Department of Labor’s draft rule does not meet long-held standards for new regulation. 


In a letter to Paul Ray, acting administrator of the Office of Information and Regulatory Affairs (OIRA), the Coalition for Paper Options says the administration should withdraw the proposal because “longstanding principles for regulatory planning and review, claimed administrative cost savings and unsubstantiated assertions do not justify government regulation.” OIRA, which is housed within the Executive Office of the President and oversees implementation of government-wide policies, is part of the Office of Management and Budget (OMB), the agency currently considering the Department of Labor’s draft rule.

The Coalition for Paper Options argues that the Department of Labor’s proposed regulation fails to meet the key principle of Executive Order 12866 stating that new regulation must address “market failure justifying new regulation,” a principle which has governed U.S. regulatory planning and review for over 25 years.


“Under the status quo, consumers who prefer their retirement plan disclosures in paper have their preference honored, and consumers who prefer electronic disclosure can opt-in to electronic delivery. Citizens who prefer electronic information are taking this option, while others continue their preference for paper-based disclosures. In any event, the current system is working,” the Coalition writes, citing AARP, FINRA and the Pew Research Center research on why workers and retirees prefer paper disclosures of “important and sensitive information.


The Coalition continued, “There is no compelling evidence that DOL knows better than the millions of workers who prefer to receive their particularly sensitive and important retirement information in paper form and have chosen not to opt out of paper information.”


The Coalition for Paper Options also notes that the Department of Labor’s proposed regulation – primarily intended to save money for plan fiduciaries – does not meet the longstanding principle in President Reagan’s Executive Order 12291 that, “unless statutory language requires otherwise, agencies may only regulate if it will do more good than harm, and maximize net benefits to the public.”


“Millions of Americans without interest in or ready access to robust internet services may never see these notices again. It is up to them, after all, to switch back to paper delivery once the proposed rule is in place. And if they miss the notice, fail to check an online account, or don’t see a notice in their spam filter, they may never see retirement plan disclosures again. This fundamental statutory obligation should not be undermined to save fiduciaries relatively minor administrative costs,” writes the Coalition for Paper Options, arguing that the proposed Department of Labor regulation even undermines the fundamental statutory duty of retirement plan fiduciaries to keep workers and retirees informed about their retirement plans. 


To read the letter 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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