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The Commission prefaces the guidelines on electronic delivery in the April 2000 Release with the statement that the existing framework in this area continues to work well and remains appropriate in the current technological environment.[4] The Commission states explicitly that issuers should continue to assess their compliance with the delivery requirements of the federal securities laws in light of the notice, access and delivery considerations established in the October 1995 Release and the May 1996 Release. The discussion in the April 2000 Release, therefore, is intended simply to clarify certain issues relating to electronic delivery... [62] See April 2000 Release, Section II.B.2., n.66. Rule 137 provides that the publication or distribution of information, opinions or recommendations in the regular course of its business by a broker-dealer not participating in a distribution is not an offer within the meaning of Section 2(a)(11) of the Securities Act. See Securities Act, Rule..