From: William F. Davis
Dear Sir:On May 4, 2006 the NASD stated on its web site that it had filed Amendment No 5 to the Code of Arbitration rewrite, Filing 2003-158. This filing includes substantial changes from the last amendment to the rewrite which will materially affect investors.
Most of my practice for the last 20 years has involved representing investors against the securities industry, and the procedural rules that the system requires that I use are the NASD Code of Arbitration Procedure. Permitting the NASD to unilaterally change the rules without input from the other side involved in this adversarial process is unfair and could be construed as industry-biased.
Based on the scores of comment letters already received on the rewrite it is
clear that this is an area of great concern to the public.. I therefore ask
that the SEC commence a new comment period to allow public input on this
important new filing,
William F. Davis