Subject: File No. SR-FINRA-2010-022
From: A.M. Miller

May 6, 2010

Increasing the number of arbitrators on lists generated by the "Neutral List Selection System" is long overdue. When is the Industry Code going to be amended relating to the make-up of arbitration panels. Currently the rules state that the only time a three person industry related panel is warranted would be when there is a dispute arising from contracts and/or commissions. This would only apply to sales individuals or registered representatives. If a compliance officer has a dispute with a member firm, why do applicable rules not allow a three person industry related panel. Public arbitrators are not familiar with potential exposure or the rules and regulations that govern the securities industry. Public arbitrators have absolutely no appreciation for the functional responsibilities of an "executive contact" or control person. The way the system is currently set-up, it discourages individuals from coming forward to tell the truth. A seasoned compliance officer deserves more than just having arbitration panels making multiple final decisions based on sensationalism and innuendo.

A.M. Miller
www.fauxcompliance.com