February 7, 2013
I am an atorney who has represented investors in securities arbitration for the last 18 years. I am also a member of PIABA a bar group of attorneys representing investors in securities arbitration. As such I am in favor of the proposed rule as an improvement of the present sysytem. However the "look-back" periods as currently drafted under the rule are unfair to investors. Thank you for this opportunity to comment.