From: Scott R. Shewan |
Ladies and Gentlemen: I am an attorney who practices regularly before the NASD in arbitration proceedings. It has come to my attention that the above rule filing seeks to overhaul the NASD Code of Arbitration Procedure. As you might imagine, an overhaul to the arbitration rules may have a significant impact on my practice and on my clients' rights. I would like an opportunity to review and digest the proposed changes, and then make comments thereto. My immediate concern is that the Rule Filing has been submitted to the SEC with a request for "Accelerated Approval," which would deprive me and other affected members of the public of any ability to comment on the rule changes. I respectfully request that the request for Accelerated Approval be denied, so that I may have an opportunity to comment. Sincerely, Scott R. Shewan |