From: Lenny Steiner
Sent: May 9, 2016
To: rule-comments@sec.gov
Subject: SR-FINRA-2016-015

I write in opposition to the proposed changes to Arbitration Rule 13904.  By way of background, I regularly represent registered representatives in promissory note cases.  It is shameful enough that FINRA already acts as a collection agency for broker dealers by suspending representatives who are unable to pay promissory note awards, which in essence forces representatives to settle promissory note cases no matter how compelling their counterclaims.  Now, the broker dealers are prevailing upon FINRA to make certain that they do not even have to pay the meager awards that are issued in favor of the representatives on those counterclaims.  It is not for FINRA to dictate how arbitrators must decide cases.  The attorneys for broker dealers are highly competent and always ask panels to offset the competing claims in rendering their final awards.  If the panel decides not to do an offset, it is not for FINRA to mandate one.  Let’s keep FINRA out of the arbitration decision process and leave it up to the arbitrators to decide.

Leonard Steiner
STEINER & LIBO
PROFESSIONAL CORPORATION
433 N. Camden Drive, Suite 730
Beverly Hills, CA 90210