05 17 10 comment ltr inability to pay defense

Public Investors Arbitration Bar Association 2010 Officers Scott R. Shewan President Peter J. Mougey Vice-President/ President-Elect May 17, 2010 Jenice L. Malecki Secretary Via Email: rule-comment@sec.gov Ryan K. Bakhtiari Treasurer Ms. Florence Harmon Deputy Secretary 2010 Directors Ryan K. Bakhtiari Securities and Exchange Commission California 100 F Street, NE Gail E. Boliver Washington, DC 20549-1090 Iowa Steven B. Caruso Re: SR-FINRA-2010-014 Rule Proposal Regarding Inability-to-Pay Defense New York Jason Doss Georgia Dear Ms. Harmon: Scott Ilgenfritz Florida On behalf of the Public Investors Arbitration Bar Association ( “PIABA”), William A. Jacobson I thank you for the opportunity to comment on the above-referenced Rule New York Proposal to amend FINRA Rule 9554 regarding the ‘Inability-to-Pay Defense’. Richard A. Lewins PIABA is a national, not-for-profit bar association comprised of more than 460 Texas attorneys, including law school professors and former regulators, who devote a Jenice L. Malecki New York significant portion of their practice to the representation of public investors in C. Thomas Mason securities arbitrations. Accordingly, our members and their clients have a strong Arizona interest in FINRA rules that protect public investors, particularly those that impact Peter J. Mougey the fairness of the arbitration process. Florida Kirk Reasonover PIABA supports the ...