December 3, 2010
Our firm, Shustak Frost and Partners, supports FINRA Rule Proposal SR-FINRA-2010-053, Amendments to the Panel Composition Rule, and Related Rules, of the Code of Arbitration Procedure for Customer Disputes. We believe the option of an all-public panel will be helpful to customer claimants in FINRA arbitration. FINRA's Public Arbitrator Pilot Program statistics over the last two years support a finding of increased fairness to investors. The Rule Proposal will help level the playing field for customer claimants. We hereby submit our recommendation that the SEC approve FINRA Rule Proposal SR-FINRA-2010-053.