OCC Responds to Request for Comment on Electronic Delivery of Information Under the Federal Securities Laws
September 22, 2026
By
Megan Cohen,General Counsel
The SEC proposed rules on July 16, 2026, that would allow Broker-Dealers and other registrants to make e-delivery the default mechanism for providing their customers with information and disclosures required under the Securities Laws. As proposed, the rule would cover the options disclosure document (ODD) produced by OCC and its Participant Exchanges.
On Sept. 21, 2026, OCC submitted a comment letter in support of the proposed rule. OCC’s letter argued that:
- Making e-delivery the default method for providing investors with the ODD would:
- Provide benefits to broker-dealers, including through reduced costs
- Not harm investors who would be able to opt out of e-delivery and continue receiving paper copies
- The proposed brief description that would accompany delivery via a statement of availability, as applied to the ODD, should simply alert investors to the new version of the ODD.