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2. FINRA’s Board of Governors’ agenda be made available to the public in advance.

3. Board minutes describing actions taken be published without delay.

4. FINRA make available to the public in advance rulemakings that the FINRA board is expected to consider.

5. FINRA arbitration and disciplinary hearings should be open to the public and reported.

Require FINRA arbitrators to make findings of fact based on the evidentiary record and demonstrate how those facts led to the award given (except with respect to very small claims). These written FINRA arbitration decisions should be subject to SEC review and limited judicial review.

Require that all SRO fines, including those imposed by FINRA, should go either to a newly established investor reimbursement fund or to the Treasury. SROs should not have a financial interest in imposing fines.

Require all SROs to conduct meaningful cost-benefit analysis as part of the rulemaking process with respect to major rules.

Require all SROs to publish rules in proposed format and seek public comment before they are submitted to the SEC or the CFTC.

Require each SRO to submit an annual report to Congress with detailed, specified information about its budget and fees; its enforcement activities (including sanctions and fines imposed by type of violation and type of firm or individual); its dispute resolution activities; and its rulemaking activities.

Congress should: Conduct annual oversight hearings on SROs. Either make FINRA, the Municipal Securities Rulemaking Board (MSRB), and the National Futures Association (NFA) “Designated Federal Entities” and establish an inspector general with respect to financial SROs, including

FINRA, the MSRB, and the NFA or place FINRA, the MSRB, and the NFA within the ambit of an existing inspector general.