Subject: File No. SR-FINRA-2013-003
From: Leonard Steiner

February 7, 2013

I have been representing public customers in NASD and FINRA arbitration proceedings for the past 25 years.

I whole heartedly support the proposed rule, as it is my belief that anyone even tangentially related to the brokerage industry and financial services community should be classified as an industry (non-public) arbitrator. Indeed, the rule does not go far enough, as the look bad period is too short.

In court, litigants would be able to question jurors to ferret out their hidden biases and prejudices. In FINRA arbitrations, the parties have nothing to look at other than a one paragraph bio and prior arbitration awards that give no inkling into the hidden biases and prejudices of arbitrators. In view of the paucity of information available to the parties, at the very least anyone who by education, training, or past or current work experiences is conected in any way to the brokerage industry should be classified as a non-public arbitrator.