Subject: File No. SR-FINRA-2010-053
From: Tom Porter
Affiliation: Law Offices of Jeffrey A. Feldman

November 30, 2010

Having represented claimants in securities arbitration for 15 years, it is great to see this rule on the verge of becoming a reality.

As arbitration continues to be mandatory, even the remotest appearance of bias, let alone actual bias, must be completely removed from the process. This rule change will go a long way toward accomplishing this.

It is my understanding that the public arbitrator pilot project has demonstrated statistically that removing the industry arbitrator results in a more fair and viable forum for the investor, resulting in less bias towards the industry and a greater number of claimant awards.

The SEC should approve this proposed rule change without hesitation.