Subject: File No. 4-502
From: Noreen M. Fitzgerald, First Vice President, Asst. Compliance Director
Affiliation: UBS Financial Services Inc.

May 25, 2005

This message is: UNCLASSIFIED

Good afternoon,

I do believe that the Petition contains requests that are worthy of consideration - however, I do not agree to abolishing the requirement that a securities industry arbitrator be assigned to each three person panel. As a securities industry arbitrator, and of course, I can only speak for myself, I firmly believe that we have much insight to offer in order to ensure a fair and equitable hearing for all parties concerned.

Thank you,

Noreen M. Fitzgerald

Noreen M. Fitzgerald
First Vice President
Asst. Compliance Director
UBS Financial Services Inc.
1000 Harbor Boulevard
Weehawken, NJ 07086-6790
Tel: (201)-352-5434
Fax: (201)-974-2532
Fax: (201)-352-6866
Noreen.Fitzgerald@ubs.com

Petition for Rulemaking

(1) abolish the requirement that a securities industry arbitrator be assigned to each three person panel hearing customer disputes or, in the alternative, require that information presented to a panel of arbitrators by the securities industry arbitrator be revealed to the parties during open hearing;

(2) require each Self-Regulatory Organization ("SRO") to train its arbitrators in applicable law;

(3) require SROs to conduct continuing evaluations of the ability of every arbitrator on their panels to perform his/her duties, including, but not limited to mandatory peer evaluations;

(4) specifically permit arbitration panel members, should they elect to do so, to conduct legal research, or, in the alternative, forbid SRO sponsored arbitration forums from restricting arbitrators from conducting legal research;

(5) require SROs to reveal in pre-dispute arbitration agreements whether their arbitrators are required to follow the law in their decision-making process, the training of their arbitrators in the law, and their process, if any, to evaluate their arbitrators on a continuing basis; and,

(6) require the SEC's Division of Market Regulation to specifically oversee SROs to determine whether they are in compliance with rules adopted pursuant to items (1) through (5), inclusive.

Noreen M. Fitzgerald
First Vice President
Asst. Compliance Director
UBS Financial Services Inc.
1000 Harbor Boulevard
Weehawken, NJ 07086-6790
Tel: (201)-352-5434
Fax: (201)-974-2532
Fax: (201)-352-6866
Noreen.Fitzgerald@ubs.com

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