Subject: File No. SR-FINRA-2008-047
From: David P. Neuman
Affiliation: Stoltmann Law Offices, P.C.

October 23, 2008

I want to thank you for the opportunity to comment on the proposed rule change, SR-FINRA-2008-047. I am an attorney who represents investors in FINRA arbitrations, and I support the adoption of the changes to NASD Rule 12401.

I believe that the proposed rule would be beneficial to all parties involved. It is obvious that parties would incur less expense and hearing fees by having one arbitrator instead of three in smaller cases. Of course, the administration of these cases would be easier when only one arbitrator is involved. Moreover, I support the rule change that allows three-arbitrator-panels only when all parties agree to such in writing.

Overall, the proposed rule change would be an improvement, and I support its adoption.


David Neuman