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