Subject: File No. SR-FINRA-2013-023
From: Seth E Lipner
Affiliation: Professor of Law, Zicklin School of Business Member, Deutsch Lipner

July 2, 2013

I write in comment to the proposed change in FINRA rules regarding arbitrator selection.

I support the proposed change. The advent of all-public panels was a significant improvement in the FINRA arbitration process. The proposal is wise because all-public panels should be the "default" selection process. The existing opt-in scheme creates needless paperwork, and is a trap for the uninitiated.

Thank you for this opportunity to comment.