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.

The reason that no claims are made against research on ETFs is that no one publishes such research. The reason no one publishes this research is because, under current law, the research might be deemed a prospectus. The reason this statutory amendment makes sense is that current law discourages the production of research that would be very useful to investors. It makes no sense to implicitly bar the production of research on one of the largest and most important investment tools in the…