Subject: File No. SR-FINRA-2009-008
From: Jan Graham
Affiliation: Graham Law Offices

April 17, 2009

I write to strongly support this rule change - a change which is long overdue. My law practice is soley the representation of public investors. There has never been a common sense reason to support the loophole which this rule change will close. If a registered person's conduct is the subject of an arbitration or court complaint, what possible reason could exist to justify not disclosing that fact on the registered person's CRD? Try explaining to clients that the registered rep who engaged in repeated sales practices violations in their accounts may have been sued for the same thing before, but we dont' have any way of knowing that unless the RR was named as a party. There are many good reasons for not naming the RR as a party, primarily as it will add a new layer of defense counsel and defense counsel strikes to good arbitrators.
This rule change is one that will greatly benefit the public investor.
Thank you for your consideration.