Subject: File No. SR-FINRA-2013-003
From: Michael S. Edmiston
Affiliation: Jonathan W. Evans Associates

February 6, 2013

We have had the pleasure and privilege of representing investors in securities arbitration matters for more than 20 years. We dedicate ourselves to assisting investors to recover losses as a result of broker misconduct. We take our work seriously and don't undertake representation unless we are convinced that a genuine wrong has been committed.

Our hard-won experience is that the outcome of a customer's arbitration case is often determined with the appointment of the arbitration panel. We have enjoyed successes with the All-Public-Arbitrator appointment system and believe it is a meaningful improvement of the securities industry's manadatory arbitration system.

The limited strikes and random name generation under FINRA'S present "Neutral List Selection System," make every "strike" count in ranking acceptable public arbitrators for a customer case. Closing the loophole which resulted in the misclassification of certain industry members, those with past or present affiliations with mutual fund companies and hedge funds, as "public" arbitrators is an incremental improvement we support.

While supporting this rule change, we also believe that additional improvements can be made in extending the look-back period for 10 years, or possibly creating a bright-line rule that any arbitrators who previously have been affiliated with the financial services industry cannot ever be classified as "public" arbitrators.

We look forward to the speedy approval of this proposed rule.

Jonathan W. Evans and Michael S. Edmiston