Subject: File No. SR-FINRA-2009-008
From: Steve A Buchwalter, Esq.
Affiliation: Attorney

April 13, 2009

I am an attorney who has represented broker-dealers, registered representatives, and customers in hundreds and hundreds of FINRA arbitrations for well over a decade.

I strongly believe it is in the investors best interest that arbitrations be fully disclosed as the new rule provides. It simply does not make sense not to pass this rule.

For those customers who do use FINRA's broker-check, arbitrations not naming the broker are not disclosed lessening the chance of a customer making an informed decision as to who to entrust their life savings.

FINRA's arbitration rules currently favor not naming the broker (as each separately represented party would get additional say so in the arbitrator selection process as well as the new ARS procedures which only apply if the broker is not named).

This rule is essential to investor protection. There is no good reason not to pass it. Especially in this time in history, investors need to be able to make informed decisions.

Steve Buchwalter