Subject: File No. SR-FINRA-2010-036
From: Rob Bleecher, Esquire
Affiliation: Pecht Associates, PC

October 14, 2010


October 14, 2010

Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-1090

Re: File No. SR-FINRA-2010-0036 Proposed Rule Change to Amend the Arbitration Codes to Permit Arbitrators to Make Referrals During an Arbitration Proceeding.

Dear Ms. Murphy:

I write in opposition to the Proposed Rule Change to Amend the Arbitration Codes to Permit Arbitrators to Make Referrals During an Arbitration Proceeding.

I am an attorney in private practice who represents investors as a part of my practice. I have experience with the securities industry and with law enforcement having worked as a Registered Representative, an Assistant District Attorney, and as a Deputy Attorney General. I am also a FINRA arbitrator and a member of the Public Investors Arbitration Bar Association.

In my view, once again, FINRA is proposing a rule change that will likely harm investors and help the industry. And the proposal is made under the guise of helping investors when in reality it will primarily harm investors and benefit the industry. In my opinion, one cannot be too cynical when it comes to analyzing the motivations behind FINRA rule proposals that affect the Dispute Resolution function of FINRA. For the many reasons cited in the comments to this Proposal made by Barry Estell, Esquire, and by Scott Shewan, Esquire on behalf of PIABA, I recommend that this rule proposal be rejected.

Sincerely,

Rob Bleecher, Esquire