Subject: File No. SR-FINRA-2011-031
From: Neal E. Nakagiri
Affiliation: President, CEO, CCO, NPB Financial Group, LLC

July 27, 2011

Given the weight and seriousness of Finra disciplinary proceedings, it seems unfair to withhold documentary evidence to those charged with alleged violations of Finra rules and/or federal securities laws. If the present system results in "testing" those federal laws that seemingly prevent disclosure of certain documents, I would prefer that the present system continue "as is". I understand Finra's efforts to streamline the disciplinary process and in particular the discovery process contained therein, but given that professional careers and the continued existence of Finra BD's is often at stake, I would recommend that every opportunity and effort be afforded to those charged in a Finra disciplinary proceeding. I think it is especially troubling if the withheld documents offer exculpatory evidence.

Neal E. Nakagiri
President, CEO, CCO
NPB Financial Group, LLC
3500 W. Olive Avenue, Suite 300
Burbank, California 91505