Subject: File No. SR-FINRA-2014-020
From: Leonard Steiner
Affiliation: Steiner & Libo

May 6, 2014

What took so long?  FINRA has known for years that these broker shenanigans have been going on and did nothing about it for years.  Only when the hue and cry in Congress and the press about the inadequacies of the CRD system became so loud that this subject could no longer be ignored did FINRA decide to act.

Here is another thing that FINRA should do immediately:  figure out a way to insure that expungement hearings are not one sided affairs in which only the broker testifies and presents evidence.  As can be well imagined, a settling claimant has little or no incentive to participate in an expungement hearing.  So typically the panel will hear only the broker’s side.  FINRA should require panels to solicit, by letter or even subpoena, testimony from the claimant as well, which will give the panel, and thus the public, at least a fighting chance of uncovering the truth.

Leonard Steiner
433 N. Camden Drive, Suite 730

Beverly Hills, CA  90210