BROADRIDGE Financial Solutions Inc. (NYSE:BR), the investor communications and fulfillment firm, has removed false claims the company made on its website about its annual reporting products being compliant with the Americans with Disabilities Act (ADA).
The changes were made after I drew attention to the poor usability of Broadridge’s online annual report and proxy statement products in an article about early problems with the SEC’s new “notice-and-access” electronic delivery system.
The article called attention to Broadridge’s false claims about its products being accessible to people with disabilities, including blind web users who rely on screen-reading software.
Prior to changing the text last week, Broadridge claimed — in bold text — that its interactive annual report product was “ADA compliant.” It also falsely said the documents were “ADA approved.” One of these statements is shown in the screenshot below. The other is shown in the earlier article.
Following the article, however, Broadridge staff replaced the ADA references with language stating that the company’s annual report product “includes accessibility features for persons with visual disabilities.” The new language is shown in the screenshot below.
Unfortunately, even Broadridge’s revised statements could be misconstrued because every document on the Web has some form of “accessibility feature.”
Significantly, Broadridge’s new language does not state that the products are actually accessible to people with visual disabilities. They simply have “accessibility features,” which is similar to saying a staircase has accessibility features if it has a handrail. True, but a staircase with a handrail still is not accessible to someone in a wheelchair.
Even so, this is a major turnaround from claiming that its product was compliant or approved by a federal government department with ADA authority. It suggests a lack of due diligence before the company rolled out its product for the new E-proxy market, which is subject to specific SEC usability requirements.
The about-face also calls into question Broadridge’s expertise in web-based communications because the problems with the technologies Broadridge is using for its online annual report and proxy statement product are not new. We and others have been reporting on the evils of image-based reports since February 2003.
The fact is image-based documents are unacceptable for essential online disclosures. They have inherently poor readability, bad design and hard-to-use navigation.
Indeed, they are the very antithesis of extensibility and flexibility that regulators are striving to achieve with their interactive data initiatives.
In that sense, image-based annual reports and proxy statements have no place in a modern securities disclosure system.