Subject: File No. SR-FINRA-2010-053
From: RAFAEL E LUGO
Affiliation: ATTORNEY AT LAW

December 3, 2010

Dear Sir or Madam:

The proposed changes in the rule, allowing the opportunity for the panel to be composed of all public arbitrators proivde the only chance for a fair ruling and determination in a securities aribtration case. Therefore I am in support of the rule change.

Cordially,

Rafael E. Lugo, Esq.