From: Herb Pounds
Sent: May 15, 2006
Subject: File No. SR-NASD-2003-158

The NASD has requested "Acclerated Approval" of Rule Filing SR-NASD-2003-158 of the proposed new Code of Arbitration Procedure with the SEC. The NASD has asked for accelerated approval without an opportunity for public comment. Given the impact any new Code of Arbitration Procedure will have on public investors for years to come, there is absolutely no legitimate reason for the SEC to approve the new code, as submitted, without giving those affected the opportunity to comment. Why does the SEC not publish the filing and afford the public an opportunity for comment?

Herb Pounds
Herbert E. Pounds, Jr., P.C.
17890 Blanco Road, Suite 100
San Antonio, Texas 78232
210.492.2915 (Fax)