Subject: File No. SR-FINRA-2013-003
From: David Harrison, Esq.
Affiliation: Law Offices of David Harrison

January 29, 2013

I am an attorney practicing mainly in securities related matters.

The proposed rule is inadequate to ensure that potential arbitrators have sufficient separation from their affiliations with the securities industry. Persons associated with a mutual fund or hedge fund should be treated as non-public arbitrators, which means a five year period for transitioning from a non-public to public arbitrator after leaving the industry and prohibit anyone who has been associated with the industry for at least twenty years from ever becoming a public arbitrator, regardless of how long ago the association ended.

Thank you for this opportunity to comment on this proposed rule.

David Harrison