Subject: File No. 265-28
From: Andrea Bailey

September 29, 2017

I have been an Arbitrator since 2004.  For  the first eleven years with FINRA, I was classified as a Public Arbitrator because I did not work in the securities industry.  In 2015 I was reclassified as a Non-Public Arbitrator due to the rule changes.  This reclassification has significantly changed my activity in the selection process.  I haven't been chosen for a case since then.  I feel that the rule change has put me into the wrong grouping. 

When I contacted FINRA about this change, I was advised that it was because I had worked over 31 years ago, briefly, for a brokerage firm. 

Since then and for the past 30 years, I have maintained all of my education, employment and expertise in the field of law.  But now, because less than 1% of my career has been outside the realm of Securities, I am being disqualified from working on a regular basis by not being allowed to be classified as a Public Arbitrator. 

Please consider this at the public meeting on October 12.

Andrea Bailey