December 29, 2009
The purpose of this letter is to provide the Securities and Exchange Commission with comments on the above referenced proposed rule change which was filed by the Financial Industry Regulatory Authority, Inc. (FINRA) on October 28, 2009.
I am an attorney whose practice is exclusively devoted to the representation of public investors in their disputes with the securities industry. Moreover, I am a past President and a current member of the Board of Directors of the Public Investors Arbitration Bar Association (PIABA)and I am also a current public member of the FINRA National Arbitration and Mediation Committee (NAMC).
It is my personal opinion that the proposed rule change, which would codify existing policy, would not only enhance the integrity and efficiency of the entire arbitration process, but would also be economically beneficial for public investors.
Accordingly, it is my personal opinion that the proposed rule change should be approved, on an accelerated basis, without any further delay.