Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-1090
Re: SR-FINRA-2009-008
Dear Ms. Murphy:
I am writing to submit my public comments on the proposed Revisions to the Forms U4 and U5. I am an attorney practicing in the Virginia/Washington, DC area, and I have spent the last nine years of my practice almost exclusively representing individual Claimants/investors in FINRA Arbitrations across the country.
I would like to adopt and support the comments of the Public Investors Arbitration Bar Association (PIABA) on these revisions, submitted by letter signed by Brian Smiley. I agree that the current CRD system needs to be revised so that representatives named in arbitration Statements of Claim or lawsuits should be required to report such an event, even if they are not a named party. Without such a revision, one is left with the current system in which Brokercheck reports obtained from the FINRA website are woefully inaccurate in regard to a representative’s complaint history.
I thank you for your consideration of these comments.
W. Scott Greco
GRECO & GRECO, P.C.
www.securities-lawyers.net