March 4, 2014
The purpose of this letter is to provide the Securities and Exchange Commission with comments on the above referenced proposed rule change which was filed by the Financial Industry Regulatory Authority, Inc. (FINRA) on February 13, 2014.
I am an attorney whose practice is exclusively devoted to the representation of individual and institutional investors in their disputes with the securities industry. Moreover, I am a former President and current Director Emeritus of the Public Investors Arbitration Bar Association (PIABA), am the former Chairman of FINRAs National Arbitration and Mediation Committee (NAMC), am the current Chairman of FINRAs Discovery Task Force Committee (DTFC) and am a former member of the Securities Investor Protection Corporation (SIPC) Modernization Task Force.
It is my personal opinion that revisions to the FINRA Code of Arbitration Procedure (FINRA Code), which would require the redaction of personal identification information from documents filed with FINRA, would be beneficial – if not critical – for public investors, the integrity of the arbitration forum and should be immediately approved by the staff of the Commission.
Thank you for providing me with the opportunity to submit my comments on this rule filing.