July 2, 2013
Thank you for the opportunity to comment on SR-FINRA-2013-023, regarding the use of the "all public panel option" in FINRA arbitration. I am an attorney who regularly represents investors in FINRA arbitration.
I am in support of the rule proposal. Since the vast majority of customers are electing to use the All Public Panel option, this should be the default option. Moreover, based on the fact that about two-thirds of customers using the All Public Panel option have not ranked any industry arbitrators, it is clear that most customers would prefer not to have an industry arbitrator presiding on their case.
Moreover, this will benefit pro se investors who may not be familiar with FINRA rules or with the arbitrator selection process.
In sum, FINRA should adopt this rule in an effort to make the arbitration process more fair. Thanks again for the opportunity to comment.