Subject: File No. SR-FINRA-2010-035
From: G Kirk Ellis
Affiliation: Retiured Corporate and Securities Lawyer

August 24, 2010

Please get rid of that portion of the proposed changes in the arbitration rules that would enable financial institutions to conduct discovery going back three years to discover all financial accounts and transactions engaged in or held by anyone who initiates an arbitration request. It is an absolute outrage A column by Seth Lipner pointed the issue out today.