From: John G. Appel, Jr.
NASD's request for "Accelerated Approval" of Rule Filing SR-NASD-2003-158 should be rejected. I request that the SEC publish NASD's proposal for public comment.
The proposed rules have had 5 amendments, the last of which is 350 pages. Obviously, the only version that counts is the one that is finally approved by the SEC. There is no reason to proceed with final SEC approval on an expedited basis. The proposed rule changes are voluminous and substantial. Time is needed to study the proposed final version.
I am a lawyer who represents securities investors. Almost without exception, these investors have no recourse but to arbitrate their claims and NASD is the organization that conducts most of the arbitrations. The NASD Rules of Arbitration Procedure have a profound effect on the rights of investors. The SEC should not approve the final version of these proposed rules before giving the public, and their lawyers, time to review the rules and make comments to the SEC.
John G. Appel, Jr.