November 26, 2010
My legal practice is entirely the representation of public investors. One of the most difficult challenges of representing public investors who have suffered investment losses is that they are highly intimidated by a forum they do not understand: FINRA Arbitration. The fact that one of the "judges" on their case must be a representative of the very industy that is on the other side aggravates that intimidation. In my opinion, this Rule Change, to allow investors a choice of an all public arbitration panel, is a critical and important change in making the process accessible to members of the public. I strongly urge the SEC to adopt the change.