Click-Here for Your Fund Report: SEC Endorses Web-Delivery and Asks for Comments

by K&L Gates LLP

K&L Gates LLP

A. Key Takeaways

On June 4, 2018, the Securities and Exchange Commission (“SEC”) adopted Rule 30e-3 (the “Rule”) to provide mutual funds, exchange-traded funds, closed-end funds and certain registered unit investment trusts covered by the rule (“Funds”) with a new option of internet-based “notice and access” delivery of annual and semi-annual shareholder reports, conditioned on delivery to investors of a separate paper notice for each shareholder report to explain how the report can be obtained from a website or in paper form. The following is a high level summary of the Rule and its conditions, including certain differences between the final Rule and the 2015 rule proposal. The first date on which any Fund may rely on the Rule to send paper notices in lieu of shareholder reports is January 1, 2021.

In related releases, two SEC requests for public comment were announced. First, the SEC seeks public comment on additional ways to modernize fund information. Investors, academics, literacy and design experts, market observers, fund advisers, and boards of directors are invited to provide feedback on how to improve the experience of fund investors. Second, the SEC seeks comment on the framework for certain processing fees that broker-dealers and other intermediaries charge funds for delivering fund shareholder reports and other materials to investors.

These requests for comments present an excellent opportunity for Fund sponsors and others to comment on specific areas relating to the investor experience, including, but not limited to: (1) the length and content of statutory and summary prospectuses, (2) the use of even more abbreviated disclosure documentation such as utilized by Canadian and European funds, (3) uniform standards for the presentation of Fund strategies and risk information, (4) the disclosure requirements of other types of funds (closed end funds, business development companies, unit investment trusts and variable insurance products), and (5) which self regulatory organization is best positioned to set and regulate fees for the mutual fund industry. Comments are due by October 31, 2018.

B. Rule 30e-3 Regulatory Context

The Rule was initially proposed in May, 2015 as part of a broader SEC rulemaking initiative focused on modernizing registered investment company reporting. In October 2016, after an extensive comment period, the SEC adopted rules related to some aspects of the modernization proposals (including new Form N-PORT, new Form N-CEN, amendments to Regulation S-X, and other form amendments relating to securities lending activities). However, proposed Rule 30e-3 proved surprisingly controversial and was not adopted, despite support from the fund industry and the potential to reduce mailing and printing costs while streamlining shareholder access to information. [1] Since that time, the SEC has continued to study the rule proposal while considering how relevant concerns could be addressed. This process ultimately led to the approval of the Rule by a majority vote of the SEC’s Commissioners on June 4, 2018, with the notable inclusion of a multi-year transition period and additional flexibility in the type of information that may be included in the paper notices to investors, as described in greater detail below. [2]

C. Impact of Final Rule 30e-3

Once the Rule is fully implemented (in January 2022), Funds will be permitted to satisfy their delivery obligations for shareholder reports in multiple ways: (1) by mailing traditional reports on paper if preferred by the funds or requested by investors, (2) through electronic delivery only to those investors who have specifically chosen this method under the SEC’s existing electronic delivery protocols, (3) by providing a short form paper notice paired with comprehensive website accessibility for each report covered by the Rule (the “notice and access” method), or (4) through a combination of the above.

D. Conditions for Reliance on Rule 30e-3

In order to avail itself of the optional “notice and access” method of delivery under the Rule, a Fund must comply with a series of key conditions. The conditions include:

  • Public Website Materials. The Fund’s most recent shareholder report and the Fund’s immediately prior report must be publicly accessible, free of charge, at a website specified for the purpose. In addition, complete quarterly portfolio holdings for the last fiscal year (i.e., holdings included in the most recent annual and semi-annual shareholder reports, plus holdings from the fund’s first and third fiscal quarters) must be publicly accessible at the same website. In adopting release relating to the Rule (“Adopting Release”) the SEC noted favorably that some fund groups have established dedicated electronic delivery website pages with FAQs, contact information, and details about obtaining documentation on paper.
  • Paper Notice. Investors must receive a short form paper notice of the availability of each shareholder report delivered pursuant to the Rule (each, a “Notice”). The Notice must: (1) include information sufficient to direct investors to the reports on the specified public website (including, for example, a prominent legend in bold-face type stating that an important report to investors is available online) and (1) provide clear instructions for obtaining a paper copy of any single report and for electing paper transmission for all future reports. In a change from the 2015 proposal, the Notice need not be accompanied by a reply card.
  • Investor Opt-Out. At any time, an investor must be permitted to elect, at no cost: (1) a print-upon-request paper copy of any individual report mandated for inclusion on the website, and (2) paper copies of all future reports, in each case by calling a toll-free telephone number or otherwise notifying the Fund or the applicable intermediary. Notably, an investor’s election to receive reports in paper format with respect to just one Fund will be deemed to apply broadly to all other Funds held in the same account.

E. Extended Transition Period

As originally proposed, Rule 30e-3 would have been effective immediately, permitting Funds to establish internet-based delivery by default so long as investors received a written notice (an ‘Initial Statement’) at least 60 days prior to the time the Fund planned to begin relying on the rule. In the final rule, the SEC abandoned the concept of the Initial Statement in favor of an extended transition period with staged effective dates over three years. The extended transition period means that January 1, 2021, is the earliest date that Notices may be mailed to investors in lieu of full paper reports. Below is a summary of the Rule’s key compliance dates:

 January 1, 2019  Effective Date of the Rule.

Investor Preference Tracking. Beginning January 1, 2019, Funds and intermediaries that intend to rely on the Rule on January 1, 2021, must track investor preferences to receive paper copies of reports from the first time they transmit or deliver a document that includes the required cover page disclosure to a shareholder.
 January 1, 2019 through December 31, 2021 (“Compliance Period”)  Cover Page Disclosures. Existing funds that intend to rely on the Rule on January 1, 2021, must provide prominent disclosures on the cover page or beginning of their summary prospectuses, cover pages of their statutory prospectuses, and front cover page or beginning of their annual and semi-annual reports, informing investors of the change in delivery format options. This disclosure must appear for two consecutive years during the three year Compliance Period. New funds that begin offering shares publicly during the period between January 1, 2019, and December 31, 2021, must include the required statements on each applicable document required to be delivered or transmitted to investors for the period beginning on the date the fund first publicly offers its shares and ending on December 31, 2021.
 January 1, 2021  Notices. The earliest date that Notices may be transmitted to investors in lieu of paper reports, assuming disclosure requirements have been met.

Form N-CSR. Effective date for amended instructions to Form N-CSR. Funds that choose to transmit an Initial Statement containing information from a shareholder report must file the Initial Statement as part of their reports on Form N-CSR.
 January 1, 2022  Temporary Disclosure Conditions Expire. Cover page and related disclosures no longer required. Funds that did not provide the required disclosure during the Compliance Period may begin relying on the Rule to provide Notices in lieu of paper reports to investors.

F. Added Flexibility for Notices

In response to comments on the 2015 rule proposal, the SEC provided in the final Rule that the Notice may, in addition to the mandatory items, include a limited amount of additional information drawn from content within the relevant shareholder report (but generally not from other filings). To aide the SEC’s compliance monitoring and information gathering efforts, as part of the Rule initiative, the SEC also adopted amendments to Form N-CSR that require Funds to make filings with the SEC of Notices that incorporate disclosures from shareholder reports.

The Adopting Release also provides flexibility as to Fund shares acquired through a variety of distribution channels, including insurance products. For example, for a Fund that is available as an investment option in a variable annuity or variable life insurance contract, the SEC has specifically permitted the Notice to accompany the contract or the contract’s statutory prospectus and statement of additional information. Similarly, the Notice is permitted to accompany an investor’s account statement delivered by a broker-dealer or another type of intermediary. Moreover, the Notice may include information identifying the Fund, its sponsor (including any investment adviser or sub-adviser to the Fund), a variable annuity or variable life insurance contract or insurance company issuer thereof, or a financial intermediary through which shares of the Fund are held.

G. Limitations on Processing Fees

Simultaneous with the adoption of the Rule, the SEC approved amendments to rules of the New York Stock Exchange (“NYSE”) regarding processing fees paid to financial intermediaries for the delivery of shareholder reports and notices to beneficial owners of Fund shares under “notice and access” rules such as the Rule. The rule amendments were approved based on proposals submitted by the NYSE in 2016 and are intended to clarify and limit certain circumstances in which “notice and access” processing fees may be charged. In addition, as noted below, the SEC has requested comment more generally on the processing fees charged for forwarding materials on behalf of Funds.

H. Additional Requests for Public Comment

Alongside the adoption of the Rule, the SEC also published two releases that seek public comment prior to a deadline of October 31, 2018.

  1. Retail Investor Experience [4] The first request for comment is directed at investors and other interested parties, seeking comments as to ways in which fund disclosure, including shareholder reports, may be improved. This input is intended to assist the SEC as it modernizes the design, delivery and content of Fund information, including shareholder reports, prospectuses, and advertisements. The SEC has also requested comments on the manner of delivery and how to make disclosure more interactive and personalized. Fund sponsors and others will want to consider submitting comments in the following specific areas:
  • Of particular interest are questions related to the statutory and summary prospectus, including whether the summary prospectus should be limited in length similar to the Canadian Facts Document or European Key Investor Information Document, whether it would be beneficial to have a one-page sheet at the beginning of each statutory prospectus (or summary prospectus) with key information such as historical performance, fees, portfolio managers, date of inception and whether the fund employs leverage to a significant extent, or whether it should include additional data points (such as measures of leverage, or derivative exposure).
  • Other questions focus on the utility of the content of prospectuses or reports such as strategies, risks, fees and expenses, performance, management discussion of fund performance, and structured disclosures such as XBRL .

    • In particular, with respect to performance, the SEC questions whether it should address the length and complexity of principal strategies disclosure or establish specific thresholds to determine which strategies are considered “principal” (such as a stated percentage of the fund’s assets devoted to a strategy).
    • With respect to risk, among other questions, the SEC asks whether Funds should list their principal risks in a way that reflects the relative importance of each risk to a Fund or simply in alphabetical order. Further, the SEC asks whether a Fund should rank its risk level akin to that required by Canadian and European regulators.
  • The SEC also asks for comments regarding mutual-fund advertising and how to appropriately tailor disclosure requirements to other types of funds including: closed-end funds, business development companies, unit investment trusts, and variable insurance products.

The SEC release also includes a short 14 question “Feedback Flier” designed specifically for retail investors to enable them to provide input in a streamlined manner.

  1. Intermediary Processing Fees [5] As noted above, with the adoption of the Rule, the SEC approved amendments to the NYSE Rules regarding processing fees paid to financial intermediaries for the delivery of shareholder reports and notices to beneficial owners of Fund shares under “notice and access” rules such as the Rule intended to clarify and limit certain circumstances in which “notice and access” processing fees may be charged. However, the SEC believes that it is appropriate to consider more broadly the overall framework and influences on the level of processing fees charged by broker-dealers and other intermediaries for forwarding shareholder reports and other non-proxy materials to Fund investors to investors that are beneficial owners of shares held in “street name” through the intermediary. The request for comment focuses on the appropriateness and treatment of these various fees (i.e., “interim report fees,” “preference management fees,” and “notice and access fees”) and other reimbursements of expenses as well as the role and compensation of fulfillment service providers.

The request also questions whether the NYSE or the Financial Industry Regulatory Association (“FINRA”) is best positioned to take on a regulatory role for setting fees in for the mutual fund industry given the NYSE’s limited involvement with mutual funds and the fact that FINRA has adopted rules that generally mirror the NYSE rules in this regard. [6] Further, FINRA has adopted rules governing broker-dealers’ sales practices and other conduct with respect to funds. [7]

As noted, the SEC seeks public comment prior to a deadline of October 31, 2018.

[1] The final rule was approved by four of the SEC’s five Commissioners (Clayton, Stein, Piwowar, and Peirce). Commissioner Jackson did not approve. Commissioner Stein expressed reservations, but ultimately approved the final rule. Each Commissioner subsequently released a public statement outlining his or her own considerations in voting, available at

[2] In this respect, the final rule provides that if an investor has notified a fund complex, or the investor’s financial intermediary, that the investor wishes to receive paper copies of shareholder reports, the investor will be deemed to have requested paper copies with respect to (i) all current and future Funds held through an account or accounts with (A) the transfer agent or principal underwriter or agent thereof for the same fund group or (B) the financial intermediary; and (ii) any and all Funds held in a separate account funding a variable annuity or variable life insurance contract.

[3] Request for Comments on Fund Retail Investor Experience and Disclosure,


[5] Request for Comments on the Processing Fees Charged by Intermediaries For Distributing Materials Other Than Proxy Materials to Fund Investors,

[6] Compare FINRA Rule 2251 with NYSE rule 451.

[7] See FINRA Rules 2341 and 2210.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© K&L Gates LLP | Attorney Advertising

Written by:

K&L Gates LLP

K&L Gates LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.