From: Henry I. Pass, Esquire
Sent: May 15, 2006
To: rule-comments@sec.gov
Subject: File No. SR-NASD-2003-158


Ladies and Gentlemen:
I wish to go on record to object to the NASD's request for Accelerated Approval of SR-NASD-2003-158. The fact that the NASD's administration of the Code of Arbitration Procedure is akin to the fox guarding the hen house is sufficient, in and of itself, to warrant the SEC publishing and filing the proposed amendments and afford the opportunity for public comment. I find it sorely unacceptable for the SEC to even consider granting approval of substantial amendments to the Code without affording impacted parties the ability to provide comments and to have the SEC consider same. In light of the impact the new Code will have on public investors for years to come, there is absolutely no legitimate rational for the SEC to even consider the proposed Code amendments in the absence of providing the requisite "due proceess' to the investing public.

Respectfully submitted,
Henry Ian Pass, Esq.

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Henry I. Pass, Esquire
The Law Offices of Henry Ian Pass
401 E. City Avenue, Suite 200
Bala Cynwyd, PA 19004
telephone 610-660-8001
facsimile 610-660-8004