March 27, 2008
I am pleased to provide the Securities and Exchange Commission with comments on the above referenced proposed rule change which was initially filed by the Financial Industry Regulatory Authority, Inc. (FINRA) on November 2, 2007 and subsequently amended on February 13, 2008.
I am an attorney whose practice is exclusively devoted to the representation of public investors in their disputes with the securities industry.
While it is my opinion that motions to dismiss should never be allowed in the context of a customer-initiated arbitration proceeding, the proposed rule change appears to be designed to substantially reduce the abusive motion tactics that have, for far too long, been permitted to be waged against the investing public when they have attempted to have their grievances aired before the members of an arbitration panel.
Accordingly, I would encourage the Commission to approve this rule change on an expedited basis.