Subject: File No. SR-NASD-2007-021
From: Daniel A. Ball, Esq.
Affiliation: Ball Law Offices, A Professional Corporation

July 25, 2007

The proposed amendment to Rule 12100(u) of the Customer Code is a much needed initiative to ensure that public arbitrators are truly public. The proposed amendment should help to cleanse the pool of public arbitrators of lawyers whose law firms derived substantial revenue from securities industry disputes with customers. The proposed amendment could be improved upon, however, if the $50,000 exemption over two years was reduced to a lesser amount or eliminated altogether.