Subject: File No. SR-FINRA-2010-053
From: Robert H Rex , Esq.
Affiliation: Attorney Practitioner and member Public Investors Arbitration Bar Association

November 29, 2010

November 29th, 2010

My practice has been devoted to the representation of individuals in FINRA arbitrations seeking recovery of losses from stockbrokers and broker dealers for over 20 years. I have elected to utilize the Pilot Program a number of times and believe it should become a permanent part of the FINRA rules. My clients have the perception that the process if more fair with the option to exclude industry arbitrators.