Subject: File No. SR-NASD-2003-158
From: Howard M Rosenfield
Affiliation: Attorney

July 14, 2005


I am an attorney that has represented Claimants in NASD arbitrations since 1989. I write in support of the PIABA comment. In addition to the public perception of bias of the industry arbitrator to the securities industry, the industry expertise that used to be present with industry arbitrators who originally were primarily compliance and supervisory personnel has been diluted with the expansion of non public arbitrators who no longer possess the broad industry expertise of the supervisory and compliance background of those who used to be industry arbitrators.

This group of non-public arbitrators now includes branch office managers, branch office administrative managers, and brokerage firm attorneys who do not share the compliance and supervisory need to ensure that industry rules are followed. The dilution of the industry arbitrator pool requires that the role of the non-public arbitrator be re-examined.

Howard Rosenfield
10 Waterside Drive
Farmington, CT 06032
860 677-4334