Subject: Definition of Public Arbitrator

August 16, 2007

I have been arbitrating securities cases since 1988. I was going to draft a comment concerning the proposed rule defining a public arbitrator, but then I read the comment by Laurence S. Schultz. I couldn't agree more nor express my feelings better. My personal opinion is that if the bias against the public continues in the securities arbitration arena as now exists, the Supreme Court will have to reverse its ruling permitting the mandated industry dispute forum.

Donald M. Feferman
Donald M. Feferman, P.C.