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Ellen MillerExecutive DirectorThe Sunlight Foundation1818 N Street, NWSuite 300Washington, DC 20036

March 8, 2012

Marcia E. AsquithOffice of the Corporate SecretaryFINRA1735 K Street, NWWashington, DC 20006-1506

Re: FINRA Requests Comment on Ways to Facilitate andIncrease Investor Use of BrokerCheck Information

Dear Ms. Asquith,

We are commenting on FINRAs February 2012 proposal onWays to Facilitate and Increase Investor Use ofBrokerCheck Information. As advocates for open data, weare disturbed that the proposal lacks any mention of makingthe data underlying FINRAs BrokerCheck website searchavailable for download in electronic, machine readableformat.

In the wake of recent scandals surrounding the pyramid

schemes of Bernie Madoff and R. Allen Stanford, of multi-

million dollar settlements by firms involved in the 2008

financial meltdown, and distrust generally of Wall Street,

it is essential that consumers know all they can about the

professionals in whom they trust their savings.

Accountability is key, and the data maintained by FINRA in

its BrokerCheck database and by the SEC in its IAPD

database are crucial to that accountability. As the SEC

wrote in its January 2011 report, Study andRecommendations on Improved Investor Access to Registration

Information About Investment Advisers and Broker-Dealers

because selecting a broker-dealer or investment adviser is

one of the most important decisions that investors face,

information to help them make this choice should be easy to

find, easy to use, and easy to understand."

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While FINRA and the SEC are to be commended for creatinginteractive searches on their websites for thisinformation, providing comprehensive access to it involves

more than building a better website with consolidatedsearches and results by zip code.

It is important that FINRA and the SEC make the dataunderlying these databases available for download inelectronic, machine readable format, so that nonprofitentities such as the Sunlight Foundation as well asjournalists and other investigators are able to gain accessand do sophisticated investigations using the information.

As it exists now, it is impossible to query these websitesto answer questions such as, Which firms have hired the

most advisers and broker/dealers with a history ofdisciplinary actions? or What is the total amount of

fines paid by a given entity over a specific time period?The web interfaces severely limit the ability ofresearchers to be nimble in their analysis.

It's been well established that bulk access to downloadabledata is a necessary to maximize reuse and analysis ofpublic disclosure information. Numerous policies anddeclarations from the Obama administrationembrace this principle, and FINRA should offer free,unrestricted access to its essential data in accordance

with open data principles.

The Sunlight Foundation strongly urges FINRA to make thesedata available to the public in such electronic formats asfacilitate this type of research.

The Sunlight Foundation

The Sunlight Foundation is a non-profit, nonpartisanorganization that uses the power of the Internet tocatalyze greater government openness and transparency, andprovides new tools and resources for media and citizens,alike. We are committed to improving access to government

information by making it available online, indeedredefining public information as meaning online, and bycreating new tools and websites to enable individuals andcommunities to better access that information and put it touse.

We want to catalyze greater government transparency byengaging individual citizens and communities --

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technologists, policy wonks, open government advocates andordinary citizens - demanding policies that will enableall of us to hold government accountable. Sunlight developsand encourages new government policies to make it more openand transparent, facilitates searchable, sortable and

machine readable databases, builds tools and websites toenable easy access to information, fosters distributedresearch projects as an community building tool, engages inadvocacy for 21st century laws to require that government

make data available in real time and trains thousands ofjournalists and citizens in using data and the web to

watchdog Washington.

Sincerely,

Ellen Miller