July 1, 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 June 17, 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 the proposed amendments to the Code of Arbitration Procedure, which would expand the scope of the non-public arbitrator definition and reorganize the presentation of both the public and non-public arbitrator definitions, would significantly address longstanding constituent perceptions about the fairness and neutrality of the public arbitrator roster and would enhance the interests of public investors.
Based on the preceding, I would, without qualification or reservation, strongly recommend that the Commission approve the proposed amendments to the Code of Arbitration Procedure on an expedited basis.
Thank you for providing me with the opportunity to submit my comments on this rule filing.