May 9, 2016
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 April 28, 2016.
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), the former Chairman of FINRAs National Arbitration and Mediation Committee (NAMC), the current Chairman of FINRAs Discovery Task Force Committee (DTFC) and a former member of the Securities Investor Protection Corporation (SIPC) Modernization Task Force.
It is my personal opinion that the proposed amendments to the By-Laws of FINRAs regulatory subsidiary, FINRA Regulation, Inc., which would expand the size of the National Adjudicatory Council to 15 members and which would, at the same time, require that the number of non-industry members exceed the number of industry members, would clearly advance the public interest and protect investors and should be approved by the SEC on an expedited basis.