Subject: File No. SR-FINRA-2010-053
From: Richard A Lewins, Esq.

December 2, 2010

I am an attorney whose practice is primarily representing investors in FINRA Arbitrations. The playing field is not level. On many levels and in many ways the investors forced to arbitrate in this forum are at a decided disadvantage. One of those disadvanges has been panel composition, specifically the requirement that one of the panel members be from the industry they are bringing a claim against. This is akin to being mugged and being required to have four members of your jury be former or current muggers.
This Rule change removes that requirement, and I am wholeheartedly in favor of it. It is not the cure -all for the system, but it is a step in the right direction.