Subject: File No. SR-NASD-2007-021
From: William P. Torngren P. Torngren
Affiliation: Attorney

August 6, 2007

I have participated in SRO securities arbitration for more than 30 years.

The proposed rule sets a $50,000 limit on income earned from the securities industry before an arbitrator is no longer public. A public arbitrator should be truly public and earn no income at all from the securities industry for services rendered. $50,000 is a substantial amount of money, and public arbitrators should not have any professional ties to the securities industry.

SRO securities arbitration for public investors should be free of any industry biases pro or con, apparent or actual. That requires elimination of (1) the industry arbitrator, (2) professionals who receive money for representing or serving as experts for either industry members or public investors in arbitration, and (3) persons who receive any income from industry sources for services rendered.

The proposed rule change should be approved with deletion of the exemption which allows somebody who is not truly a public arbitrator to be classified as a public arbitrator. Nonetheless, and absent that deletion, the proposed rule change still is a step in the right direction in reducing the appearance of bias inherent in earning money from the very industry which an arbitrator ultimately adjudges. The goal of the SEC should be a truly public pool of public arbitrators free from any apparent bias based upon the persons whom they serve.

I also join in the comments submitted by the North American Securities Administrators Association and the Public Investor Arbitration Bar Association.

Thank you for your consideration of this comment.

William P. Torngren
117 J Street, Suite 300
Sacramento, CA 95814
Telephone: (916) 554-6447
Facsimile: (916) 554-6445