From: Scott I. Batterman, Esq. |
Clay Chapman Crumpton Iwamura & Pulice I am writing to object to the request by the NASD for Accelerated Approval" of Rule Filing SR-NASD-2003-158. This filing relates to a proposed new Code of Arbitration Procedure. The request for accelerated approval would deprive the public of the opportunity to comment on these new rules. This is inappropriate. The new Code of Arbitration Procedure will affect thousands of investors for years to come. There is no legitimate reason to approve the new code, as submitted, without giving those affected the opportunity to weigh in. Accordingly, I request that the SEC reject the NASD's request for what would amount to secret rule-making, and publish the filing, so as to afford an opportunity for public comment. Scott I. Batterman, Esq. Clay Chapman Crumpton Iwamura & Pulice Telephone (808) 535-8400 |