In November 2013, the Staff of the Division of Investment Management of the SEC published a Guidance Update in response to recent questions about whether funds that make distributions to their shareholders from any sources other than net income may electronically deliver the “written statement” required by Section 19(a) of the 1940 Act describing the sources of those distributions. The Staff’s view is that funds may electronically deliver the required “written statement,” so long as the electronic delivery complies with the Staff’s other electronic delivery guidance (i.e., notice, access and evidence of delivery).
The Guidance Update is available at www.sec.gov/divisions/investment/guidance/im-guidance-2013-11.pdf.