The Consumer Federation of America expresses strong support for FINRA’s proposed rule to implement the Comprehensive Automated Risk Data System (CARDS). With this proposal, FINRA seeks to bring its broker-dealer oversight and examination program into the 21st Century, utilizing modern data analysis techniques to uncover potential fraud and abuse more quickly and efficiently. By collecting data in a standardized format and on a regular basis across all firms that are subject to CARDS, this new system should make it easier for FINRA to identify patterns of conduct that indicate possible abuses and target its oversight resources accordingly. It would in our view be irresponsible for FINRA not to move forward with this sort of modernization of its oversight program.