May 23, 2016
I am the immediate past FINRA Director of Arbitration, having retired in 2013. I submit this comment with respect to SR-FINRA-2016-015 (Proposed Rule Change to Permit Award Offsets in Arbitration). For the reasons articulated below I believe the proposed rule should be approved.
While the number of cases that would be impacted directly by the proposed rule are few in number, and very few of those would involve investor claims, clarity is always a good thing. The proposed change would also provide useful guidance to parties in terms of drafting their pleadings, and thus impact a larger number of cases.
I urge the Commission to approve the proposed new rule.