Subject: File No. SR-FINRA-2009-057
From: Daniel W. Roberts
Affiliation: President/CEO, Roberts & Ryan Investments Inc.

October 5, 2009

having reviewed the federal register in some detail, i find many references to finra as a "self regulatory organization" for purposes of requesting sec agreement to rule changes. the fact of the matter is that once finra staff espoused and achieved the removal of one vote per member for each seat on the natioal board of governors, nasd (alias finra) ceased to be an "sro" for regulatory purposes under the maloney act. therefore finra does not have any special standing to recommend bylaw changes . in order to eliminate what is a regulatory void please return with negative comment the above referenced filing and encourage and assist finra membership to regain status as a national association of broker dealers (sro) by reinstating members rights to direct the organization ( one vote for each national board of governors seats). all have witnessed that regulation without industry input is a non starter and disasterous for the investing public. dan roberts

Daniel W. Roberts

Roberts & Ryan Investments Inc.
57 Post Street, Suite 614
San Francisco, CA 94104-5023
Member - SIPC, FINRA