Subject: File No. SR-FINRA-2009-050
From: Seth E Lipner
Affiliation: Prof of Law, Zicklin School of Business, Baruch College, CUNY

August 27, 2009

I write to comment on the proposal to amend the FINRA public disclosure rule.

While I endorse any expanasion of public disclosure, I urge the SEC to require FINRA to eliminate entirely the 2-year purge provision.

An investor's decision to entrust hard-earned money to a particular broker should be based on all that is know-able. The purge provision reduces that which is know-able.

FINRA states that in adopting the 2-year purge provision, it is compromising the interests of investors and the interests of brokers. When it comes to disclosure, I do not
believe that compromise is appropriate. If compromise or balancing is adopted, however, the time limit shoud be 10 years, not the ultra-short 2 years in the current proposal.

Thank you for this opportunity to comment