Subject: File No. SR-FINRA-2009-008
From: Leonard Steiner
Affiliation: Lawyer

April 13, 2009

I applaud the SEC on its long overdue proposal to require broker-dealers to report against brokers arbitrations or court suits where the broker is not named as a party respondent or defendant but is the subject of the statement of claim or complaint. This change finally closes an enormous gap in the reporting system.

On the other hand, I do not understand the proposal to increase the reporting minimum from $10,000 to $15,000. One of the purposes of reporting is to enable members of the public to make informed decisions as to the honesty and integrity of brokers. Thus, the nature of a broker's purported misconduct is more important than the size of the settlement resulting from the purported misconduct. In my view, there should be no minimum reporting threshhold. Certainly, the current threshhold should not be increased.