Voya Financial, Inc. (NYSE: VOYA) has submitted a comment letter to the U.S. Securities and Exchange Commission supporting the agency's proposal to modernize electronic delivery of required investor disclosures.

The SEC's current framework defaults to paper delivery. Voya's letter outlines several recommended changes to the proposed rule aimed at improving implementation without reducing investor protections.

Among Voya's recommendations, the company suggests replacing two similar paper transition notices with a single notice, and eliminating or shortening the proposed 180-day waiting period before electronic delivery takes effect. Investors would retain the ability to request paper documents or opt out of electronic delivery.

Voya also recommends allowing firms to use electronic addresses obtained through employers, retirement plans, affiliates, and service providers, provided the intended use is clearly disclosed. The company said this would reduce duplicative enrollment steps for retirement plan participants.

On document access, Voya proposes permitting investors to reach required materials through a secure home page or document center rather than requiring direct links to individual documents in every instance, citing evolving cybersecurity and authentication practices.

Voya further recommends allowing firms to redirect failed electronic deliveries to a valid secondary electronic address previously provided by the investor, to help maintain timely access to information.

"Digital communication is not only what people increasingly expect – it can improve investors' access to information, strengthen security and support a more personalized experience," said Amy Vaillancourt, president of Retirement at Voya Financial.

Voya said it supports retaining the proposal's core investor protections, including the ability to request paper copies, update electronic addresses, and opt out of electronic delivery.