One problem with the proposal is the distinction it makes between traditional and nontraditional activities. This distinction is based upon the time in which a particular type of financial activity was created and the substance of the activity. For example, entering into swap transactions (particularly as to rates and currencies) and clear swaps and futures should be viewed as core banking activities: they are activities that are completely about credit intermediation. To assert that…

Firms should be mindful of procedures that will be affected by the shortening of the settlement cycle, which will not be limited to the rules listed above. For example, the margin timing requirements also will be impacted.

NASAA should be commended for moving towards a uniform set of rules relating to electronic delivery. That said, the notion that today's investors must give specific consent for the electronic delivery of documents is just so twentieth century (and not even late twentieth century). At a minimum, investors should be deemed to have given consent if they respond to an electronic communication (and they could still have the ability to opt out). By acknowledging that electronic communications are…

Firms are advised to take this offer seriously, as there is no doubt that Commissioner J. Christopher Giancarlo would like to make changes that would bring down the expenses of doing business. While an invitation to rethink a larger part of the rule structure would be more alluring than a KISS, it's only a first date.