Subject: File No. SR-FINRA-2009-050
From: John Miller
Affiliation: Attorney, Swanson Midgley, LLC, Kansas City, MO

September 9, 2009

I have represented customers in securities arbitration for the past twenty years. It is vital that investors, parties in arbitration, and the general public have as much information available as possible regarding their brokers and investment advisors. A broker's CRD should not be purged simply because the broker has been out of the business for two years. The information should be available for at least 10 years, or at a minimum six years, which corresponds to FINRA's "six-year rule" for bringing an arbitration claim. FINRA's role of investor protection is diminished by this proposal, and it should be rejected.