March 2, 2012
The purpose of this letter is to provide the Securities and Exchange Commission with comments on the above referenced proposed rule change which was filed by the Financial Industry Regulatory Authority, Inc. (FINRA) on February 9, 2012.
I am an attorney whose practice is exclusively devoted to the representation of public investors in their disputes with the securities industry. Moreover, I am a former President and a former member of the Board of Directors of the Public Investors Arbitration Bar Association (PIABA) and am the current Chairman of FINRAs National Arbitration and Mediation Committee (NAMC).
It is my personal opinion that the proposed revisions to the FINRA Code of Arbitration Procedure (FINRA Code), which would increase the limit for arbitration proceedings that would be handled under the simplified arbitration rules that are set forth in the FINRA Code, from the current threshold level of $25,000 in damages (exclusive of interest and costs) to the proposed threshold level of $50,000 in damages (exclusive of interest and costs), would be beneficial for public investors and should be immediately approved by the staff of the Commission.