Self-Regulatory Organizations; New York Stock Exchange LLC.; Order Approving Proposed Rule Change and Amendment No. 1 Thereto to Rule 607 Relating to the Classification of Arbitrators as Public or Industry, 54102-54104 [E6-15187]
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54102
Federal Register / Vol. 71, No. 177 / Wednesday, September 13, 2006 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[File No. 500–1]
In the Matter of Southwestern Medical
Solutions, Inc.; Order of Suspension of
Trading
September 11, 2006.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of
Southwestern Medical Solutions, Inc.
(‘‘Southwestern’’), a non-reporting
issuer quoted on the Pink Sheets under
the ticker symbol SWNM, because of
questions regarding the accuracy and
adequacy of assertions by Southwestern,
and by others, concerning, among other
things: (1) The existence of applications
for U.S. Food and Drug Administration
approvals for its Labguard product, (2)
the existence of a patent and trademark,
and (3) the receipt of an order for the
sale of several thousand units of
Labguard.
The Commission is of the opinion that
the public interest and the protection of
investors require a suspension of trading
in the securities of the above-listed
company.
Therefore, it is ordered, pursuant to
Section 12(k) of the Securities Exchange
Act of 1934, that trading in the
securities of the above-listed company is
suspended for the period from 9:30 a.m.
EST, September 11, 2006 through 11:59
p.m. EST, on September 22, 2006.
By the Commission.
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. 06–7654 Filed 9–11–06; 12:03 pm]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–54407; File No. SR–NYSE–
2005–43]
Self-Regulatory Organizations; New
York Stock Exchange LLC.; Order
Approving Proposed Rule Change and
Amendment No. 1 Thereto to Rule 607
Relating to the Classification of
Arbitrators as Public or Industry
September 6, 2006.
hsrobinson on PROD1PC61 with NOTICES
I. Introduction
On June 17, 2005, the New York Stock
Exchange, Inc. (‘‘NYSE’’ or the
‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’), pursuant to section
19(b)(1) of the Securities Exchange Act
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18:14 Sep 12, 2006
Jkt 208001
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
amend Rule 607 relating to the
classification of arbitrators as public or
industry. On August 4, 2005, the
Exchange filed Amendment No. 1 to the
proposed rule change.3 In this
amendment, the Exchange stated that
the rule change will become effective 90
days following the publication of this
order in the Federal Register. The NYSE
will update and reclassify arbitrators
during this time period. The proposed
rule change was published for comment
in the Federal Register on August 29,
2005,4 and the Commission received 38
comments on the proposal.5 The
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 In Amendment No. 1, which supplemented the
original filing, the Exchange modified the
implementation date for the proposed rule change
and clarified certain aspects of the filing.
4 See Exchange Act Release No. 52314 (Aug. 22,
2005), 70 FR 51104 (Aug. 29, 2005).
5 Several commenters filed letters regarding the
amendments to Exchange Rule 607 in connection
with the proposed change to NASD Rule 10308
(NASD 2005–094), which also governs non-public/
industry and public arbitrators. The NYSE and the
Commission have identified letters in response to
both rule filings that address the proposed changes
to NYSE Rule 607.
See letters from Bradford D. Kaufman, Esq.,
Greenberg Traurig, dated Oct. 7, 2005 (‘‘Kaufman’’);
Jonathan W. Evans, Esq., Jonathan W. Evans &
Associates, dated Sept. 21, 2005 (‘‘Evans’’); L.
Jerome Stanley, dated Sept. 20, 2005 (‘‘Stanley’’);
Thomas D. Mauriello, Law Offices of Thomas D.
Mauriello, dated Sept. 20, 2005 (‘‘Mauriello’’);
William P. Torngren, Law Offices of William P.
Torngren, dated Sept. 20, 2005 (‘‘Torngren’’); Jason
R. Doss, Page Perry, LLC, dated Sept. 20, 2005
(‘‘Doss’’); Brian M. Greenman, Esq., dated Sept. 20,
2005 (‘‘Greenman’’); Teresa M. Gillis, Shustak, Jalil
& Heller, dated Sept. 20, 2005 (‘‘Gillis’’); Susan N.
Perkins, Esq., dated Sept. 20, 2005 (‘‘Perkins’’);
Charles C. Mihalek, Esq. and Steven M. McCauley,
Esq., Charles Mihalek, P.S.C., dated Sept. 20, 2005
(‘‘Mihalek’’); Steven J. Gard, Esq., Gard, Smiley,
Bishop & Dovin LLP, dated Sept. 20, 2005 (‘‘Gard’’);
Scott L. Silver, Blum & Silver, LLP., dated Sept. 20,
2005 (‘‘Silver’’); Mitchell S. Ostwald, Esq., Law
Offices of Mitchell S. Ostwald, dated Sept. 20, 2005
(‘‘Ostwald’’); Joel A. Goodman, Esq., Goodman &
Nekvasil, P.A., dated Sept. 20, 2005 (‘‘Goodman’’);
Alan C. Friedberg, Pendleton, Friedberg, Wilson &
Hennessey, P.C., dated Sept. 19, 2005 (‘‘Friedberg’’);
Debra G. Speyer, Law Offices of Debra G. Speyer,
dated Sept. 19, 2005 (‘‘Speyer’’); Harvey H. Eckart,
Eckart & Leonetti, P.A., dated Sept. 19, 2005
(‘‘Eckart’’); G. Mark Brewer, Esq., Brewer Carlson,
LLP, dated Sept. 19, 2005 (‘‘Brewer’’); Steve A.
Buchwalter, first letter dated Sept. 19, 2005 and
second letter dated Sept. 13, 2005 (‘‘Buckwalter’’);
Royal B. Lea, III, Esq., Bingham & Lea, and Randall
A. Pulman, Esq., Pulman, Bresnahan & Pullen, LLP,
dated Sept. 19, 2005 (‘‘Lea’’); Richard P. Ryder,
Securities Arbitration Commentator, Inc., dated
Sept. 19, 2005 (‘‘Ryder’’); Eliot Goldstein, Esq.,
dated Sept. 19, 2005 (‘‘Goldstein’’); Philip M.
Aidikoff, Aidikoff & Uhl, dated Sept. 16, 2005
(‘‘Aidikoff’’); Bruce E. Baldinger, Esq., Baldinger &
Levine, L.L.C., dated Sept. 16, 2005 (‘‘Baldinger’’);
Henry D. Fellows, Jr., Fellows Johnson & La Briola,
LLP, dated Sept. 16, 2005 (‘‘Fellows’’); Rosemary J.
Shockman, Public Investors Arbitration Bar
Association, dated Sept. 15, 2005 (‘‘PIABA’’); James
D. Keeney, dated Sept. 15, 2005 (‘‘Keeney’’); Bill
2 17
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majority of commenters are lawyers that
represent investors in arbitrations. This
order approves the proposed rule
change as amended.
II. Description of the Proposal
Arbitration panels for disputes
involving customers or non-members in
which the damages are alleged to exceed
$25,000 are comprised of three
arbitrators: Two public arbitrators and
one from the securities industry. A
customer or non-member also may
request at least a majority of arbitrators
from the securities industry.
Exchange Rule 607(a)(2) currently
classifies an arbitrator as from the
securities industry if he or she: (1) Is, or
within the past five years was,
associated with certain entities related
to the securities industry (or retired
from, or spent a substantial part of his
or her career with such an entity); (2) is
an attorney or other professional who
devoted 20 percent or more of his or her
work effort to securities industry clients
within the past two years; or (3) is
registered under the Commodity
Exchange Act, or is a member of a
registered futures association or any
commodity exchange or is associated
with any such person.
Exchange Rule 607(a)(3) currently
classifies an arbitrator who is not from
the securities industry as a public
arbitrator. However, a person cannot be
classified as a public arbitrator if he or
she has a spouse or household member
who is associated with certain entities
related to the securities industry.
The NYSE is concerned that some
arbitrators currently classified as public
have affiliations with entities that have
securities industry ties such as banks,
insurance companies, mutual funds,
holding companies and asset
management firms. In an effort to
enhance investor confidence in the
NYSE arbitration forum, and in order to
further ensure that persons serving as
public arbitrators do not have ties to the
securities industry or related firms, the
Exchange proposed to amend Rule 607.
Fynes, dated Sept. 15, 2005 (‘‘Fynes’’); Jay A.
Salamon, Hermann, Cahn & Schneider LLP, dated
Sept. 14, 2005 (‘‘Salamon’’); Jorge A. Lopez, Esq.,
Law Offices of Jorge A. Lopez, P.A., dated Sept. 14,
2005 (‘‘Lopez’’); Steven B. Caruso, Esq., Maddox
Hargett & Caruso, P.C., dated Sept. 14, 2005
(‘‘Caruso’’); Scott C. Ilgenfritz, dated Sept. 14, 2005
(‘‘Ilgenfritz’’); Tracey Pride Stoneman, Tracey Pride
Stoneman, P.C., dated Sept. 14, 2005 (‘‘Stoneman’’);
Michael J. Willner, Miller Faucher and Cafferty
LLP, dated Sept. 13, 2005 (‘‘Willner’’); Richard M.
Layne, Layne & Lewis, LLP, dated Sept. 13, 2005
(‘‘Layne’’); Michael Knoll, Esq., Law Offices of
Michael Knoll, dated Sept. 13, 2005 (‘‘Knoll’’); John
J. Miller, Law Offices of John J. Miller, P.C., dated
Sept. 13, 2005 (‘‘Miller’’); and Seth E. Lipner,
Professor of Law, Zicklin School of Business Baruch
College and Member, Deutsch & Lipner, dated Sept.
8, 2005 (‘‘Lipner’’).
E:\FR\FM\13SEN1.SGM
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Federal Register / Vol. 71, No. 177 / Wednesday, September 13, 2006 / Notices
The proposed amendments would: (1)
Expand the list of entities engaged in
the securities business by adding certain
membership categories not previously
specifically mentioned (but,
nevertheless, contemplated by the
current rule), and by adding a catch-all
for any ‘‘other organization engaged in
the securities business;’’ 6 (2) preclude
any individual who is associated with
any entity that controls, is controlled by,
or is under common control with an
entity on the expanded list from being
classified as a public arbitrator; and (3)
preclude any individual from being
classified as a public arbitrator who has
an immediate family member associated
with an entity on the expanded list. The
amendment would also define which
persons are included within the term
‘‘immediate family member.’’
In order to ensure the integrity of the
classification of public arbitrators, the
Exchange will update and reclassify
arbitrators in compliance with the
amended rule if approved.
III. Summary of Comments
The Commission received 38 letters
on the proposal.7 Several commenters
believed that the changes proposed were
laudatory.8 Many, nonetheless, viewed
the proposed amendments as
insufficient to address what they
considered as an arbitration process that
is unfair to investors. Their concern
generally centered in three areas: (1)
The inclusion of any industry arbitrators
on arbitration panels; (2) the criteria for
qualifying as a public arbitrator; and (3)
the desire to harmonize NYSE and
NASD rules on this issue.9
hsrobinson on PROD1PC61 with NOTICES
Inclusion of Industry Arbitrators
The majority of commenters
expressed the view that the mandatory
inclusion of arbitrators from the
securities industry on arbitration panels
creates an unfair burden for investors
seeking redress, and stated that
arbitration panels should be comprised
only of individuals with no ties to the
securities industry.10 A number of
commenters maintained that the
mandatory inclusion of securities
6 These organizations would include any entity
engaging in securities transactions, including banks
and other financial institutions. Telephone
conversation among Karen Kupersmith, Director of
Arbitration, NYSE; Lourdes Gonzalez, Assistant
Chief Counsel—Sales Practices, SEC; and Michael
Hershaft, Special Counsel, SEC (July 26, 2006).
7 See footnote 5.
8 See, e.g., Ilgenfritz, Stoneman, Buchwalter,
Willner, and PIABA.
9 See Ryder
10 See, e.g., Willner, Caruso, Knoll, PIABA,
Ilgenfritz, Buchwalter, Mauriello, Torngren,
Aidikoff, Doss, Brewer, Lea, Speyer, Keeney,
Stanley, Layne, Baldinger, Eckart, and Fellows.
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16:19 Sep 12, 2006
Jkt 208001
industry arbitrators creates a perception,
rightly or wrongly, that the process is
unfair and biased against investors.
Their suggestion was to eliminate the
securities industry arbitrator.11 One
commenter opined that, in cases where
special expertise is important, the
securities industry arbitrator becomes a
de facto expert witness, providing the
public arbitrators with his or her
opinion in secret, and depriving
investors of due process because they
and their counsel would have notice of
or a chance to rebut the opinion.12
Criteria for Public Arbitrators
Several commenters also stated that
the proposed rule change would not
adequately preclude persons with ties to
the securities industry from meeting the
definition of public arbitrator.13
Currently, Rule 607(a)(2)(iv) permits an
attorney, accountant or other
professional to serve as a public
arbitrator if that person has devoted less
than 20 percent of his or her work to
securities industry clients within the
last two years.14
Some commenters favored amending
the definition of public arbitrator to
exclude all attorneys, accountants or
other professionals who have
represented the securities industry.15
One commenter stated that arbitrators
with industry ties have an ‘‘inherent
bias’’ in favor of the industry, and noted
that the rule currently allows persons
with industry bias, such as an attorney
with ties to the securities industry, to
serve on panels ‘‘under the guise of
being public.’’ 16 Another commenter
maintained that attorneys with industry
ties who serve as public arbitrators
would have a vested interest in keeping
monetary awards low.17
Harmonizing NYSE and NASD Rules
One commenter expressed concern
that the proposed rule change would
‘‘differ significantly’’ from the Uniform
Code of Arbitration (‘‘UCA’’)
classification rule, and stated that the
NYSE rule change and NASD’s proposal
to amend its rule on the same subject
should have been ‘‘brought to the
Commission with the same text after
11 See,
e.g., Torngren and Lewis.
Willner.
13 See, e.g., Evans, Caruso, Lipner and Lopez.
14 Several commenters explicitly or implicitly
cited to NASD Rule 10308(a)(5)(A)(iv), which
prohibits an attorney, accountant or other
professional whose firm derived 10 percent or more
of its annual revenue in the past two years from
securities activities instead of the NYSE limitation.
See, e.g., PIABA, Stoneman, Buchwalter, Salamon,
and Keeney.
15 See, e.g., Evans and Caruso.
16 See Lopez.
17 See Lipner.
12 See
PO 00000
Frm 00086
Fmt 4703
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54103
being vetted by [the Securities Industry
Conference on Arbitration (‘‘SICA’’)].’’ 18
In this commenter’s view, the SEC
should ‘‘at least compel’’ the NYSE and
NASD to develop ‘‘identical solutions’’
to this issue.19
IV. NYSE Response to Comments
Responding to commenters’ concerns,
the NYSE noted that securities industry
arbitrators add value to the arbitration
process.20 It also stated that, as the
administrator of a neutral forum, it
believes public investors, non-members
and members should have input into
procedures by which arbitrators are
appointed. Moreover, NYSE is a
member of SICA, and it will continue to
consider any rule changes regarding
panel compositions that SICA may
adopt to the UCA.
The NYSE also stated that the 20
percent limitation on the securities
activities of public arbitrators allows
individuals that have minimal ties to
the securities industry to serve as
arbitrators. In its view a complete bar on
professionals with any ties to the
securities industry could also prohibit
professionals who primarily represent
public investors from serving on
arbitration panels.
Acknowledging commenters’
concerns regarding ties public
arbitrators have to the securities
industry, the NYSE also indicated that
it will review the definition of public
arbitrator to address persons whose
firms receive a percentage of revenue
derived from securities industry clients.
NYSE stated that it will propose a
separate rule amendment to prohibit
certain individuals from serving as
public arbitrators if their firms receive a
certain percentage of revenue from
securities industry clients, which would
be similar to the current restrictions in
NASD Rule 10308.
In addressing the specific differences
between its proposed rule change and
the rule change proposed by NASD, the
NYSE stated that it defined ‘‘immediate
family’’ and ‘‘control’’ to ensure that
18 See
Ryder.
In particular, this highlighted the
differences in who would be considered an
‘‘immediate family member’’ under each rule.
While the NYSE rule would exclude immediate
family members of associated persons, the NASD
rule would exclude immediate family members of
all control-related parties. In addition, the NYSE
definition of immediate family member would
include in-laws, while the NASD definition would
not. Moreover, the NASD include step-relatives,
while the NYSE rule would not. Finally, while the
NYSE definition of ‘‘control’’ would not extend to
the immediate family of the ‘‘control-related
parties,’’ the NASD’s definition would.
20 See Letter from Mary Yeager, NYSE, to
Katherine A. England, SEC, dated June 5, 2006
(‘‘Yeager’’).
19 Id.
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54104
Federal Register / Vol. 71, No. 177 / Wednesday, September 13, 2006 / Notices
people with perceived ties to the
securities industry would not be defined
as public arbitrators, while avoiding
eliminating from the arbitrator pool
individuals with minimal ties to the
securities industry.
Finally, the NYSE stated that
alternatives to panel composition and
the method by which arbitrators are
classified are beyond the scope of this
rule filing. It therefore declined to
address these issues at this time.21 The
NYSE also stated that it is prepared to
discuss those issues at the appropriate
time.22
VI. Conclusion
It is therefore ordered, pursuant to
section 19(b)(2) of the Act 25 that the
proposed rule change (SR–NYSE–2005–
43), as amended, be, and hereby is,
approved.
V. Discussion and Commission Findings
SECURITIES AND EXCHANGE
COMMISSION
After careful review, the Commission
finds that the proposed rule change, as
amended, is consistent with the Act
and, in particular, with section 6(b)(5) of
the Act, which requires, among other
things, that the NYSE’s rules be
designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, and, in general, to protect
investors and the public interest.23
The Commission believes that the
proposed rule change will promote the
public interest by limiting certain
people who have ties to the securities
industry from serving as public
arbitrators. In particular, by expanding
the list of entities engaged in the
securities business and companies they
control, the rule will further limit the
industry ties the public arbitrator may
have. The new definition of ‘‘immediate
family member’’ should have a similar
result.24
The Commission appreciates the
comments suggesting the elimination of
securities industry arbitrators, and the
further restriction on persons who have
any ties to the securities industry from
serving as public arbitrators. While
these comments are beyond the scope of
this rule filing, they raise important
questions regarding the arbitration
process. We understand that SICA is
actively considering proposals from its
membership regarding these issues. We
note that the NYSE has stated it will
review any rule regarding panel
composition that SICA adopts to the
UCA, and that it will propose a separate
amendment further limiting the
definition of public arbitrator.
21 Id.
hsrobinson on PROD1PC61 with NOTICES
22 Id.
23 15
U.S.C. 78f(b)(5).
19(b)(2) of the Act requires the
Commission to approve a proposed rule change if
it finds that the proposed rule change is consistent
with the requirements of the Act, and the applicable
rules and regulations thereunder. This standard
does not require the NYSE, NASD or SICA rules to
be identical.
24 Section
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16:19 Sep 12, 2006
Jkt 208001
For the Commission, by the Division of
Market Regulation, pursuant to delegated
authority.26
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E6–15187 Filed 9–12–06; 8:45 am]
BILLING CODE 8010–01–P
[Release No. 34–54408; File No. SR–DTC–
2006–12]
Self-Regulatory Organizations; The
Depository Trust Company; Notice of
Filing and Immediate Effectiveness of
a Proposed Rule Change Relating to
the LENS Service
September 6, 2006.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 notice is hereby given that on
July 28, 2006, the Depository Trust
Company (‘‘DTC’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared primarily by DTC. DTC filed
the proposed rule change pursuant to
Section 19(b)(3)(A) of the Act 2 and Rule
19b–4(f)(4) 3 thereunder so that the
proposal was effective upon filing with
the Commission. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The proposed rule change will
discontinue the posting of Asset-Backed
Security notices on DTC’s LENS system.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
DTC included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
25 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 15 U.S.C. 78s(b)(3)(A).
3 17 CFR 240.19b–4(f)(4).
26 17
PO 00000
Frm 00087
Fmt 4703
Sfmt 4703
may be examined at the places specified
in Item IV below. DTC has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.4
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In 1991, DTC created the LENS
service to reduce the amount of paper
that participants received in connection
with DTC’s distribution of legal and
other notices. Participants consequently
could access such notices through
DTC’s proprietary PTS 3270 terminal
network.5 In 2000, DTC enhanced this
process by making the LENS service
available over the Internet.6 Benefits of
the LENS service include: (a) Reducing
distribution costs that are born by
participants and (b) allowing for other
enhancements relating to notice
distribution, including: (i) The
identification of CUSIP numbers, (ii)
participants’ ability to search by CUSIP,
(iii) participant access to a computer
record of past notices with automatic
order capability, and (iv) equitable
billing (e.g. a participant only pays for
those notices that it orders).
Recently, DTC has studied whether
additional enhancements and
efficiencies can be brought to the LENS
service in terms of the value to
participants of the information provided
them through LENS and the associated
costs. As part of this process, DTC
reviewed a current practice relating to
the posting of Asset-Backed Security
(‘‘ABS’’) notices on LENS.7 Such ABS
notices are now generally available over
the Internet on the agents’ Web sites and
have been retrieved by DTC and posted
on LENS at considerable expense. In
light of the accessibility of ABS notices
from other sources and the expense
incurred by DTC in retrieving the
information, DTC consulted with many
of the participants with current
subscriptions to the ABS portion of
LENS and learned that DTC’s posting of
this information on LENS is of limited
value versus the alternative of
participants being able to obtain much
4 The Commission has modified the text of the
summaries prepared by DTC.
5 Securities Exchange Act Release No. 29291
(June 12, 1991), 56 FR 28190 (June 19, 1991) [File
No. SR–DTC–91–08].
6 Securities Exchange Act Release No. 34–43964
(Feb. 14, 2001), 66 FR 1190 (Feb. 22, 2001) [File No.
SR–DTC–2000–18].
7 ABS notices provide investment and financial
information specific to a respective ABS (e.g.,
monthly principal and interest factors, credit
worthiness, etc.).
E:\FR\FM\13SEN1.SGM
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Agencies
[Federal Register Volume 71, Number 177 (Wednesday, September 13, 2006)]
[Notices]
[Pages 54102-54104]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-15187]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-54407; File No. SR-NYSE-2005-43]
Self-Regulatory Organizations; New York Stock Exchange LLC.;
Order Approving Proposed Rule Change and Amendment No. 1 Thereto to
Rule 607 Relating to the Classification of Arbitrators as Public or
Industry
September 6, 2006.
I. Introduction
On June 17, 2005, the New York Stock Exchange, Inc. (``NYSE'' or
the ``Exchange'') filed with the Securities and Exchange Commission
(``SEC'' or ``Commission''), pursuant to section 19(b)(1) of the
Securities Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to amend Rule 607 relating to the
classification of arbitrators as public or industry. On August 4, 2005,
the Exchange filed Amendment No. 1 to the proposed rule change.\3\ In
this amendment, the Exchange stated that the rule change will become
effective 90 days following the publication of this order in the
Federal Register. The NYSE will update and reclassify arbitrators
during this time period. The proposed rule change was published for
comment in the Federal Register on August 29, 2005,\4\ and the
Commission received 38 comments on the proposal.\5\ The majority of
commenters are lawyers that represent investors in arbitrations. This
order approves the proposed rule change as amended.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ In Amendment No. 1, which supplemented the original filing,
the Exchange modified the implementation date for the proposed rule
change and clarified certain aspects of the filing.
\4\ See Exchange Act Release No. 52314 (Aug. 22, 2005), 70 FR
51104 (Aug. 29, 2005).
\5\ Several commenters filed letters regarding the amendments to
Exchange Rule 607 in connection with the proposed change to NASD
Rule 10308 (NASD 2005-094), which also governs non-public/industry
and public arbitrators. The NYSE and the Commission have identified
letters in response to both rule filings that address the proposed
changes to NYSE Rule 607.
See letters from Bradford D. Kaufman, Esq., Greenberg Traurig,
dated Oct. 7, 2005 (``Kaufman''); Jonathan W. Evans, Esq., Jonathan
W. Evans & Associates, dated Sept. 21, 2005 (``Evans''); L. Jerome
Stanley, dated Sept. 20, 2005 (``Stanley''); Thomas D. Mauriello,
Law Offices of Thomas D. Mauriello, dated Sept. 20, 2005
(``Mauriello''); William P. Torngren, Law Offices of William P.
Torngren, dated Sept. 20, 2005 (``Torngren''); Jason R. Doss, Page
Perry, LLC, dated Sept. 20, 2005 (``Doss''); Brian M. Greenman,
Esq., dated Sept. 20, 2005 (``Greenman''); Teresa M. Gillis,
Shustak, Jalil & Heller, dated Sept. 20, 2005 (``Gillis''); Susan N.
Perkins, Esq., dated Sept. 20, 2005 (``Perkins''); Charles C.
Mihalek, Esq. and Steven M. McCauley, Esq., Charles Mihalek, P.S.C.,
dated Sept. 20, 2005 (``Mihalek''); Steven J. Gard, Esq., Gard,
Smiley, Bishop & Dovin LLP, dated Sept. 20, 2005 (``Gard''); Scott
L. Silver, Blum & Silver, LLP., dated Sept. 20, 2005 (``Silver'');
Mitchell S. Ostwald, Esq., Law Offices of Mitchell S. Ostwald, dated
Sept. 20, 2005 (``Ostwald''); Joel A. Goodman, Esq., Goodman &
Nekvasil, P.A., dated Sept. 20, 2005 (``Goodman''); Alan C.
Friedberg, Pendleton, Friedberg, Wilson & Hennessey, P.C., dated
Sept. 19, 2005 (``Friedberg''); Debra G. Speyer, Law Offices of
Debra G. Speyer, dated Sept. 19, 2005 (``Speyer''); Harvey H.
Eckart, Eckart & Leonetti, P.A., dated Sept. 19, 2005 (``Eckart'');
G. Mark Brewer, Esq., Brewer Carlson, LLP, dated Sept. 19, 2005
(``Brewer''); Steve A. Buchwalter, first letter dated Sept. 19, 2005
and second letter dated Sept. 13, 2005 (``Buckwalter''); Royal B.
Lea, III, Esq., Bingham & Lea, and Randall A. Pulman, Esq., Pulman,
Bresnahan & Pullen, LLP, dated Sept. 19, 2005 (``Lea''); Richard P.
Ryder, Securities Arbitration Commentator, Inc., dated Sept. 19,
2005 (``Ryder''); Eliot Goldstein, Esq., dated Sept. 19, 2005
(``Goldstein''); Philip M. Aidikoff, Aidikoff & Uhl, dated Sept. 16,
2005 (``Aidikoff''); Bruce E. Baldinger, Esq., Baldinger & Levine,
L.L.C., dated Sept. 16, 2005 (``Baldinger''); Henry D. Fellows, Jr.,
Fellows Johnson & La Briola, LLP, dated Sept. 16, 2005
(``Fellows''); Rosemary J. Shockman, Public Investors Arbitration
Bar Association, dated Sept. 15, 2005 (``PIABA''); James D. Keeney,
dated Sept. 15, 2005 (``Keeney''); Bill Fynes, dated Sept. 15, 2005
(``Fynes''); Jay A. Salamon, Hermann, Cahn & Schneider LLP, dated
Sept. 14, 2005 (``Salamon''); Jorge A. Lopez, Esq., Law Offices of
Jorge A. Lopez, P.A., dated Sept. 14, 2005 (``Lopez''); Steven B.
Caruso, Esq., Maddox Hargett & Caruso, P.C., dated Sept. 14, 2005
(``Caruso''); Scott C. Ilgenfritz, dated Sept. 14, 2005
(``Ilgenfritz''); Tracey Pride Stoneman, Tracey Pride Stoneman,
P.C., dated Sept. 14, 2005 (``Stoneman''); Michael J. Willner,
Miller Faucher and Cafferty LLP, dated Sept. 13, 2005 (``Willner'');
Richard M. Layne, Layne & Lewis, LLP, dated Sept. 13, 2005
(``Layne''); Michael Knoll, Esq., Law Offices of Michael Knoll,
dated Sept. 13, 2005 (``Knoll''); John J. Miller, Law Offices of
John J. Miller, P.C., dated Sept. 13, 2005 (``Miller''); and Seth E.
Lipner, Professor of Law, Zicklin School of Business Baruch College
and Member, Deutsch & Lipner, dated Sept. 8, 2005 (``Lipner'').
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II. Description of the Proposal
Arbitration panels for disputes involving customers or non-members
in which the damages are alleged to exceed $25,000 are comprised of
three arbitrators: Two public arbitrators and one from the securities
industry. A customer or non-member also may request at least a majority
of arbitrators from the securities industry.
Exchange Rule 607(a)(2) currently classifies an arbitrator as from
the securities industry if he or she: (1) Is, or within the past five
years was, associated with certain entities related to the securities
industry (or retired from, or spent a substantial part of his or her
career with such an entity); (2) is an attorney or other professional
who devoted 20 percent or more of his or her work effort to securities
industry clients within the past two years; or (3) is registered under
the Commodity Exchange Act, or is a member of a registered futures
association or any commodity exchange or is associated with any such
person.
Exchange Rule 607(a)(3) currently classifies an arbitrator who is
not from the securities industry as a public arbitrator. However, a
person cannot be classified as a public arbitrator if he or she has a
spouse or household member who is associated with certain entities
related to the securities industry.
The NYSE is concerned that some arbitrators currently classified as
public have affiliations with entities that have securities industry
ties such as banks, insurance companies, mutual funds, holding
companies and asset management firms. In an effort to enhance investor
confidence in the NYSE arbitration forum, and in order to further
ensure that persons serving as public arbitrators do not have ties to
the securities industry or related firms, the Exchange proposed to
amend Rule 607.
[[Page 54103]]
The proposed amendments would: (1) Expand the list of entities
engaged in the securities business by adding certain membership
categories not previously specifically mentioned (but, nevertheless,
contemplated by the current rule), and by adding a catch-all for any
``other organization engaged in the securities business;'' \6\ (2)
preclude any individual who is associated with any entity that
controls, is controlled by, or is under common control with an entity
on the expanded list from being classified as a public arbitrator; and
(3) preclude any individual from being classified as a public
arbitrator who has an immediate family member associated with an entity
on the expanded list. The amendment would also define which persons are
included within the term ``immediate family member.''
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\6\ These organizations would include any entity engaging in
securities transactions, including banks and other financial
institutions. Telephone conversation among Karen Kupersmith,
Director of Arbitration, NYSE; Lourdes Gonzalez, Assistant Chief
Counsel--Sales Practices, SEC; and Michael Hershaft, Special
Counsel, SEC (July 26, 2006).
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In order to ensure the integrity of the classification of public
arbitrators, the Exchange will update and reclassify arbitrators in
compliance with the amended rule if approved.
III. Summary of Comments
The Commission received 38 letters on the proposal.\7\ Several
commenters believed that the changes proposed were laudatory.\8\ Many,
nonetheless, viewed the proposed amendments as insufficient to address
what they considered as an arbitration process that is unfair to
investors. Their concern generally centered in three areas: (1) The
inclusion of any industry arbitrators on arbitration panels; (2) the
criteria for qualifying as a public arbitrator; and (3) the desire to
harmonize NYSE and NASD rules on this issue.\9\
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\7\ See footnote 5.
\8\ See, e.g., Ilgenfritz, Stoneman, Buchwalter, Willner, and
PIABA.
\9\ See Ryder.
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Inclusion of Industry Arbitrators
The majority of commenters expressed the view that the mandatory
inclusion of arbitrators from the securities industry on arbitration
panels creates an unfair burden for investors seeking redress, and
stated that arbitration panels should be comprised only of individuals
with no ties to the securities industry.\10\ A number of commenters
maintained that the mandatory inclusion of securities industry
arbitrators creates a perception, rightly or wrongly, that the process
is unfair and biased against investors. Their suggestion was to
eliminate the securities industry arbitrator.\11\ One commenter opined
that, in cases where special expertise is important, the securities
industry arbitrator becomes a de facto expert witness, providing the
public arbitrators with his or her opinion in secret, and depriving
investors of due process because they and their counsel would have
notice of or a chance to rebut the opinion.\12\
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\10\ See, e.g., Willner, Caruso, Knoll, PIABA, Ilgenfritz,
Buchwalter, Mauriello, Torngren, Aidikoff, Doss, Brewer, Lea,
Speyer, Keeney, Stanley, Layne, Baldinger, Eckart, and Fellows.
\11\ See, e.g., Torngren and Lewis.
\12\ See Willner.
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Criteria for Public Arbitrators
Several commenters also stated that the proposed rule change would
not adequately preclude persons with ties to the securities industry
from meeting the definition of public arbitrator.\13\ Currently, Rule
607(a)(2)(iv) permits an attorney, accountant or other professional to
serve as a public arbitrator if that person has devoted less than 20
percent of his or her work to securities industry clients within the
last two years.\14\
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\13\ See, e.g., Evans, Caruso, Lipner and Lopez.
\14\ Several commenters explicitly or implicitly cited to NASD
Rule 10308(a)(5)(A)(iv), which prohibits an attorney, accountant or
other professional whose firm derived 10 percent or more of its
annual revenue in the past two years from securities activities
instead of the NYSE limitation. See, e.g., PIABA, Stoneman,
Buchwalter, Salamon, and Keeney.
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Some commenters favored amending the definition of public
arbitrator to exclude all attorneys, accountants or other professionals
who have represented the securities industry.\15\ One commenter stated
that arbitrators with industry ties have an ``inherent bias'' in favor
of the industry, and noted that the rule currently allows persons with
industry bias, such as an attorney with ties to the securities
industry, to serve on panels ``under the guise of being public.'' \16\
Another commenter maintained that attorneys with industry ties who
serve as public arbitrators would have a vested interest in keeping
monetary awards low.\17\
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\15\ See, e.g., Evans and Caruso.
\16\ See Lopez.
\17\ See Lipner.
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Harmonizing NYSE and NASD Rules
One commenter expressed concern that the proposed rule change would
``differ significantly'' from the Uniform Code of Arbitration (``UCA'')
classification rule, and stated that the NYSE rule change and NASD's
proposal to amend its rule on the same subject should have been
``brought to the Commission with the same text after being vetted by
[the Securities Industry Conference on Arbitration (``SICA'')].'' \18\
In this commenter's view, the SEC should ``at least compel'' the NYSE
and NASD to develop ``identical solutions'' to this issue.\19\
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\18\ See Ryder.
\19\ Id. In particular, this highlighted the differences in who
would be considered an ``immediate family member'' under each rule.
While the NYSE rule would exclude immediate family members of
associated persons, the NASD rule would exclude immediate family
members of all control-related parties. In addition, the NYSE
definition of immediate family member would include in-laws, while
the NASD definition would not. Moreover, the NASD include step-
relatives, while the NYSE rule would not. Finally, while the NYSE
definition of ``control'' would not extend to the immediate family
of the ``control-related parties,'' the NASD's definition would.
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IV. NYSE Response to Comments
Responding to commenters' concerns, the NYSE noted that securities
industry arbitrators add value to the arbitration process.\20\ It also
stated that, as the administrator of a neutral forum, it believes
public investors, non-members and members should have input into
procedures by which arbitrators are appointed. Moreover, NYSE is a
member of SICA, and it will continue to consider any rule changes
regarding panel compositions that SICA may adopt to the UCA.
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\20\ See Letter from Mary Yeager, NYSE, to Katherine A. England,
SEC, dated June 5, 2006 (``Yeager'').
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The NYSE also stated that the 20 percent limitation on the
securities activities of public arbitrators allows individuals that
have minimal ties to the securities industry to serve as arbitrators.
In its view a complete bar on professionals with any ties to the
securities industry could also prohibit professionals who primarily
represent public investors from serving on arbitration panels.
Acknowledging commenters' concerns regarding ties public
arbitrators have to the securities industry, the NYSE also indicated
that it will review the definition of public arbitrator to address
persons whose firms receive a percentage of revenue derived from
securities industry clients. NYSE stated that it will propose a
separate rule amendment to prohibit certain individuals from serving as
public arbitrators if their firms receive a certain percentage of
revenue from securities industry clients, which would be similar to the
current restrictions in NASD Rule 10308.
In addressing the specific differences between its proposed rule
change and the rule change proposed by NASD, the NYSE stated that it
defined ``immediate family'' and ``control'' to ensure that
[[Page 54104]]
people with perceived ties to the securities industry would not be
defined as public arbitrators, while avoiding eliminating from the
arbitrator pool individuals with minimal ties to the securities
industry.
Finally, the NYSE stated that alternatives to panel composition and
the method by which arbitrators are classified are beyond the scope of
this rule filing. It therefore declined to address these issues at this
time.\21\ The NYSE also stated that it is prepared to discuss those
issues at the appropriate time.\22\
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\21\ Id.
\22\ Id.
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V. Discussion and Commission Findings
After careful review, the Commission finds that the proposed rule
change, as amended, is consistent with the Act and, in particular, with
section 6(b)(5) of the Act, which requires, among other things, that
the NYSE's rules be designed to prevent fraudulent and manipulative
acts and practices, to promote just and equitable principles of trade,
and, in general, to protect investors and the public interest.\23\
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\23\ 15 U.S.C. 78f(b)(5).
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The Commission believes that the proposed rule change will promote
the public interest by limiting certain people who have ties to the
securities industry from serving as public arbitrators. In particular,
by expanding the list of entities engaged in the securities business
and companies they control, the rule will further limit the industry
ties the public arbitrator may have. The new definition of ``immediate
family member'' should have a similar result.\24\
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\24\ Section 19(b)(2) of the Act requires the Commission to
approve a proposed rule change if it finds that the proposed rule
change is consistent with the requirements of the Act, and the
applicable rules and regulations thereunder. This standard does not
require the NYSE, NASD or SICA rules to be identical.
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The Commission appreciates the comments suggesting the elimination
of securities industry arbitrators, and the further restriction on
persons who have any ties to the securities industry from serving as
public arbitrators. While these comments are beyond the scope of this
rule filing, they raise important questions regarding the arbitration
process. We understand that SICA is actively considering proposals from
its membership regarding these issues. We note that the NYSE has stated
it will review any rule regarding panel composition that SICA adopts to
the UCA, and that it will propose a separate amendment further limiting
the definition of public arbitrator.
VI. Conclusion
It is therefore ordered, pursuant to section 19(b)(2) of the Act
\25\ that the proposed rule change (SR-NYSE-2005-43), as amended, be,
and hereby is, approved.
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\25\ 15 U.S.C. 78s(b)(2).
\26\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Market Regulation,
pursuant to delegated authority.\26\
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E6-15187 Filed 9-12-06; 8:45 am]
BILLING CODE 8010-01-P