The following Letter Type A, or variations thereof, was submitted by individuals or entities.

Letter Type A:

As an independent financial advisor, I support regulatory efforts that aim to protect investors while maintaining an efficient regulatory environment for industry participants. I wish to applaud FINRA for seeking to restore fairness to the arbitrator selection process and making changes to the classification of non-public arbitrators. Specifically, FINRA`s decision to expand the definition of non-public arbitrators to include professionals who serve parties in investment or financial industry disputes is a welcome and important change to restore balance to the classification of these individuals. Absent the amendments, some professionals would continue to serve as public arbitrators when they have the same arguable bias as industry arbitrators. This creates an asymmetry in the application of FINRA`s rules. This change will ensure that the arbitration process and arbitration classification remains fair for all participants.

While these changes are welcome and important, I have some concern with regard to another change that FINRA is advancing in this proposal. Under the current rules, an individual who was once affiliated with the securities industry may requalify as a public arbitrator after a five year cooling off period. FINRA is proposing to eliminate the cooling off period, permanently banning individuals with industry experience from ever serving as a public arbitrator, while providing the cooling off period to professionals who serve investors. I fear that this change will reduce the chance that skilled and capable arbitrators with industry experience can impart valuable knowledge in an arbitration proceeding. This is particularly important in large and complex cases, where these individuals can use their industry background to help to inform and educate other panelists. While I understand FINRA`s concern with regard to impartiality, I believe that this decision poses unintended consequences that will have an unnecessary negative impact on arbitration proceedings and ultimately hurt investor claimants. Again, I applaud FINRA for proposing this important rule change but suggest that FINRA reconsider this one aspect of its proposal.

Thank you for considering my comments.

http://www.sec.gov/comments/sr-finra-2014-028/finra2014028-5.htm