SIFMA submitted comments on FINRA's "Proposal to Provide Web-Based Delivery of Regulatory Element of Continuing Education Requirement." Although SIFMA expressed its "strong support" for the proposal, it also recommended that FINRA: (i) encourage global usage by addressing how it will verify the identities of users who do not have social security numbers, (ii) provide "clarification on how it will handle reasonably foreseeable technology and operational issues that may arise with the implementation and use of the Web-based CE program," and (iii) specify "the level of information that will be

SIFMA expressed support for proposed rules to require the delivery of a FINRA-created educational communication to the customers of transferring representatives. In particular, SIFMA expressed support for FINRA's efforts to craft simple disclosures in plain English that would permit investors to make more informed choices. SIFMA also made the following suggestions: FINRA should address various operational challenges in order to better align the proposal's direct and indirect costs with FINRA's stated goals. The proposal's supplementary material should include exceptions in order to narrow the

SIFMA supports FINRA's proposed amendment to NASD Rule 1032(f), which would replace the Equity Trader registration category and qualification examination (Series 57) with those of a Securities Trader. SIFMA also supports the proposed amendment to NASD Rule 1022(a), which would establish a Securities Trader Principal registration category. SIFMA suggested that (i) the timeline for implementing them should be flexible enough to allow for other regulatory actions that use firms' resources and (ii) FINRA should coordinate its Series 57 proposal and the Algorithmic Trading Proposal. See: SIFMA's

The SEC published amendments in the Federal Register to regulations under the Freedom of Information Act. The amendments would allow the SEC to collect fees that reflected its actual costs, add an appeals timeframe, and clarify other matters. These adopted amendments will be effective on August 14, 2015. See: 80 FR 41432. Related news: SEC Proposes Rules under Freedom of Information Act (June 20, 2014).

SIFMA submitted a comment letter to the MSRB concerning its "Request for Comment on Draft Amendments and Other Issues Related to MSRB Rule A-3 on Membership on the Board." SIFMA expressed its general support for the proposed amendments to MSRB Rule A-3, which it said would provide greater flexibility "in recruiting individuals to serve in the independent board seat required to be an investor representative." One of the existing tests of independence requires that a board member not be associated with a regulated entity that derives a substantial portion of its revenue from investment