Subject: File No. SR-FINRA-2011-016
From: Seth E. Lipner

April 18, 2011

I am a member of Deutsch Lipner, a law firm representing investors in arbitration. I am also Professor of Law at the Zicklin School of Business (Baruch College, CUNY) in New York City

The effective date of the Rule should not be delayed. Investors need the protection and clarity afforded by the new rule now, not in the future. The securities industry, recently responsible for destroying so many investors' retirements, should not be given the benefit of any delay.