From: Daniel E. Bacine
I understand that the NASD has requested accelerated approval for proposed substantial revisions to its Code of Arbitration Procedure. The proposed changes are not simply ministerial or perfunctory. Given the impact of these changes on those who participate in the system, I believe that accelerated approval -- without a period of time for public comment -- is inconsistent with sound regulatory principles. Accordingly, I urge the SEC to publish the proposed rule changes for public comment.
Thank you for your consideration.
Daniel E. Bacine