Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving Proposed Rule Change To Amend the Customer and Industry Codes of Arbitration Procedure To Revise the Public Arbitrator Definition, 21449-21452 [2013-08323]
Download as PDF
Federal Register / Vol. 78, No. 69 / Wednesday, April 10, 2013 / Notices
obligations. The Exchange does not
believe that removing this functionality
will disincentivize Market Makers from
posting more aggressive quotes. Rather,
the Exchange believes that, similar to
the market maker quoter, Market Makers
will use the Market Maker Peg Order to
satisfy the Exchange’s quoting
requirements, while continuing to enter
and manage more aggressively priced
orders using existing order types.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
The Exchange does not believe that
the proposed rule change will impose
any burden on competition not
necessary or appropriate in furtherance
of the purposes of the Act. To the
contrary, the proposed changes to the
Market Maker Peg Order type
functionality will further align the
Exchange’s functionality with that
offered by certain other competing
market centers. Specifically, the rule
change proposed herein is based on
Nasdaq Rule 4751(f)(15) and EDGX Rule
11.5(c)(15).11 By adopting changes to
functionality to align with functionality
in place elsewhere, as well as
simplifying such functionality, the
Exchange believes that it is reducing the
potential for confusion amongst market
participants.
The Exchange has requested that the
Commission waive the 30-day operative
delay. The Commission believes that
waiving the 30-day operative delay is
consistent with the protection of
investors and the public interest. Doing
so will allow the Exchange to make the
improvements and clarifications to the
Market Maker Peg Order effective
immediately and address any technical
or operative issues that member
organizations may experience if the
Exchange’s implementation of Market
Maker Peg Order is different from that
of other exchanges.
Therefore, the Commission designates
the proposal operative upon filing.14
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
under Section 19(b)(2)(B) 15 of the Act to
determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
21449
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–BATS–
2013–022 and should be submitted on
or before May 1, 2013.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The Exchange has neither solicited
nor received written comments on the
proposed rule change.
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.16
Kevin M. O’Neill,
Deputy Secretary.
Electronic Comments
[FR Doc. 2013–08330 Filed 4–9–13; 8:45 am]
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Because the foregoing proposed rule
change does not significantly affect the
protection of investors or the public
interest, does not impose any significant
burden on competition, and, by its
terms, does not become operative for 30
days from the date on which it was
filed, or such shorter time as the
Commission may designate, it has
become effective pursuant to Section
19(b)(3)(A) of the Act 12 and Rule 19b–
4(f)(6) thereunder.13
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–BATS–2013–022 on the
subject line.
BILLING CODE 8011–01–P
Paper Comments
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change To Amend the
Customer and Industry Codes of
Arbitration Procedure To Revise the
Public Arbitrator Definition
TKELLEY on DSK3SPTVN1PROD with NOTICES
11 See
Securities Exchange Act Release Nos.
67203 (June 14, 2012), 77 FR 37086 (June 20, 2012)
(SR NASDAQ–2012–066); 67959 (October 2, 2012),
77 FR 61449 (October 9, 2012) (SR–EDGX–2012–
44); 68596 (January 7, 2013), 78 FR 2477 (January
11, 2013) (SR–EDGX–2012–49).
12 15 U.S.C. 78s(b)(3)(A).
13 17 CFR 240.19b–4(f)(6). In addition, Rule 19b–
4(f)(6)(iii) requires the Exchange to give the
Commission written notice of the Exchange’s intent
to file the proposed rule change, along with a brief
description and text of the proposed rule change,
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• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–BATS–2013–022. This file
number should be included on the
at least five business days prior to the date of filing
of the proposed rule change, or such shorter time
as designated by the Commission. The Exchange
has satisfied this requirement.
14 For purposes only of waiving the 30-day
operative delay, the Commission has considered the
proposed rule’s impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
15 15 U.S.C. 78s(b)(2)(B).
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–69297; File No. SR–FINRA–
2013–003]
April 4, 2013.
I. Introduction
On January 4, 2012, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (‘‘SEC’’ or
‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
16 17
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CFR 200.30–3(a)(12).
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of 1934 (‘‘Exchange Act’’ or ‘‘Act’’) 1 and
Rule 19b–4 thereunder,2 a proposed rule
change to amend FINRA’s Customer and
Industry Codes of Arbitration Procedure
(collectively, the ‘‘Codes’’) to revise the
definition of ‘‘public arbitrator’’ in the
Codes. Specifically, the proposed rule
change would (a) exclude persons
associated with a mutual fund or hedge
fund from serving as public arbitrators
and (b) require individuals to wait for
two years after ending certain
affiliations before they may be permitted
to serve as public arbitrators. The
proposed rule change was published for
comment in the Federal Register on
January 17, 2013.3 The Commission
received 45 comment letters on the
proposed rule change,4 and a response
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Exchange Act Release No. 68632 (Jan. 11,
2013), 78 FR 3925 (Jan. 17, 2013) (‘‘Notice’’). The
comment period closed on February 7, 2013.
4 See Letter from Steven B. Caruso, Maddox
Hargett & Caruso, dated Jan. 16, 2013 (‘‘Caruso
Letter’’); letter from David Neuman, Stoltmann Law
Offices, dated Jan. 16, 2013 (‘‘Neuman Letter’’);
letter from Richard M. Layne, Law Office of Richard
M. Layne, dated Jan. 28, 2013 (‘‘Layne Letter’’);
letter from Seth E. Lipner, Professor of Law,
Zickloin School of Business, Baruch College, and
Member, Deutsch & Lipner, dated Jan. 29, 2013
(‘‘Lipner Letter’’); letter from Carl J. Carlson,
Tousley Brain Stephens, dated Jan. 29, 2013
(‘‘Carlson Letter’’); letter from David Harrison, Law
Offices of David Harrison, dated Jan. 29, 2013
(‘‘Harrison Letter’’); letter from Philip M. Aidikoff,
dated Jan. 29, 2013 (‘‘Aidikoff Letter’’); letter from
Scott L. Silver, Silver Law Group, dated Jan. 30,
2013 (‘‘Silver Letter’’); letter from Robert A. Uhl,
Adjunct Professor of Law, Securities Arbitration
and Director, Pepperdine Investor Advocacy Clinic,
and Partner, Aidikoff, Uhl & Bakhtiari, dated Jan.
30, 2013 (‘‘Uhl Letter’’); letter from Andrew A.
Lipkowitz, Student Intern, and Christine Lazaro,
Acting Director, St. John’s University School of Law
Securities Arbitration Clinic, dated Feb. 4, 2013
(‘‘St. John’s Letter’’); letter from Robert C. Port,
Cohen Goldstein Port & Gottlieb, dated Feb. 5, 2013
(‘‘Port Letter’’); letter from Lisa A. Catalano, dated
Feb. 5, 2013 (‘‘Catalano Letter’’); letter from Scott
R. Shewan, Pape & Shewan, dated Feb. 6, 2013
(‘‘Shewan Letter’’); letter from Jon C. Furgison, Law
Offices of Jon C. Furgison, dated Feb. 6, 2013
(‘‘Furgison Letter’’); letter from Steven J. Gard,
Reznicsek Fraser White & Shaffer, dated Feb. 6,
2013 (‘‘Gard Letter’’); letter from Jonathan W. Evans
and Michael S. Edmiston, Jonathan W. Evans &
Associates, dated Feb. 6, 2013 (‘‘Evans and
Edmiston Letter’’); letter from Robert Savage,
Visiting Assistant Clinical Professor, Florida
International University College of Law, dated Feb.
7, 2013 (‘‘Savage Letter I’’); letter from Robert
Savage dated Feb. 7, 2013 (‘‘Savage Letter II’’); letter
from James A. Dunlap, Jr., James A. Dunlap Jr. &
Associates, dated Feb. 7, 2013 (‘‘Dunlap Letter’’);
letter from Diane Nygaard, Kenner, Schmitt &
Nygaard, dated Feb. 7, 2013 (‘‘Nygaard Letter’’);
letter from W. Scott Greco, Greco & Greco, dated
Feb. 7, 2013 (‘‘Greco Letter’’); letter from A. Heath
Abshure, NASAA President and Arkansas
Securities Commissioner, dated Feb. 7, 2013
(‘‘NASAA Letter’’); letter from Robert S. Banks, Jr.,
Banks Law Office, dated Feb. 7, 2013 (‘‘Banks
Letter’’); letter from Dale Ledbetter, Esq., Ledbetter
and Associates, dated Feb. 7, 2013 (‘‘Ledbetter
Letter’’); letter from Scott C. Ilgenfritz, President,
Public Investors Arbitration Bar Association, dated
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to comments from FINRA.5 This order
approves the proposed rule change.
II. Description of the Proposal
As stated in the Notice, FINRA
classifies arbitrators under the Codes as
either ‘‘non-public’’ (otherwise known
as ‘‘industry’’ arbitrators) or ‘‘public.’’
Arbitrators are generally considered
non-public if they are affiliated with the
securities industry either because they
(1) are currently or were formerly
employed in a securities business; or (2)
provide professional services to
securities businesses. Arbitrators are
generally considered public if they (1)
do not have any significant affiliation
with the securities industry; and (2) are
not related to anyone with a significant
affiliation with the securities industry.
To improve investor confidence in the
neutrality of FINRA’s public arbitrator
roster, FINRA has amended its arbitrator
definitions a number of times over the
years.
In 2004, FINRA amended the
definitions of ‘‘public arbitrator’’ and
‘‘non-public arbitrator’’ to:
Feb. 7, 2013 (‘‘PIABA Letter’’); letter from Elizabeth
Zeck, Willoughby & Hoefer, dated Feb. 7, 2013
(‘‘Zeck Letter’’); letter from James A. Sigler, dated
Feb. 7, 2013 (‘‘Sigler Letter’’); letter from Robert W.
Goehring, dated Feb. 7, 2013 (‘‘Goehring Letter’’);
letter from William S. Shepherd, Shepherd Smith
Edwards & Kantas, dated Feb. 7, 2013 (‘‘Shepherd
Letter’’); letter from Leonard Steiner, Beverly Hills,
California, dated Feb. 7, 2013 (‘‘Steiner Letter’’);
letter from Joseph Fogel, Fogel & Associates, dated
Feb. 7, 2013 (‘‘Fogel Letter’’); letter from Richard A.
Lewins, dated Feb. 7, 2013 (‘‘Lewins Letter’’); letter
from Jenice L. Malecki, Malecki Law, dated Feb. 7,
2013 (‘‘Malecki Letter’’); letter from Mark E.
Sanders, Halling & Cayo, dated Feb. 7, 2013
(‘‘Sanders Letter’’); letter from Jeffrey Sonn, Sonn &
Erez, dated Feb. 7, 2013 (‘‘Sonn Letter’’); letter from
Thomas C. Costello, dated Feb. 7, 2013 (‘‘Costello
Letter’’); letter from Barry D. Estell, dated Feb. 7,
2013 (‘‘Estell Letter’’); letter from Royal Lea, dated
Feb. 7, 2013 (‘‘Lea Letter’’); letter from Peter
Mougey, Levin, Papantonio, Thomas, Mitchell,
Rafferty & Proctor, dated Feb. 7, 2013 (‘‘Mougey
Letter’’); letter from William A. Jacobson, Associate
Clinical Professor, Cornell Law School, and
Director, Cornell Securities Law Clinic, and
Malavika Rao, Cornell Law School ‘14, dated Feb.
7, 2013 (‘‘Cornell Letter’’); letter from David T.
Bellaire, Executive Vice President and General
Counsel, Financial Services Institute, dated Feb. 7,
2013 (‘‘FSI Letter’’); letter from Theodore M. Davis,
dated Feb. 8, 2013 (‘‘Davis Letter’’); letter from
Nicholas J. Guiliano, dated Feb. 8, 2013 (‘‘Guiliano
Letter’’); letter from Mitchell Ostwald, dated Feb. 8,
2013 (‘‘Ostwald Letter’’); letter from Charles
Michael Tobin, The Tobin Law Firm, dated Feb 22,
2013 (‘‘Tobin Letter’’). Comment letters are
available at https://www.sec.gov.
5 See Letter from Margo A. Hassan, Assistant
Chief Counsel, FINRA Dispute Resolution, to
Elizabeth M. Murphy, Secretary, Commission, dated
Mar. 11, 2013 (‘‘Response Letter’’). The text of the
proposed rule change and a copy of FINRA’s
Response Letter are available on FINRA’s Web site
at https://www.finra.org, at the principal office of
FINRA, and at the Commission’s Public Reference
Room. A copy of the Response Letter is also
available on the Commission’s Web site at https://
www.sec.gov.
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• Increase from three years to five
years the amount of time necessary after
leaving the securities industry to
transition from a non-public to public
arbitrator;
• Clarify that ‘‘retired’’ from the
industry includes anyone who spent a
substantial part of his or her career in
the industry;
• Prohibit anyone who has been
associated with the industry for at least
twenty years from ever becoming a
public arbitrator, regardless of how long
ago the association ended;
• Exclude from the definition of
‘‘public arbitrator’’ attorneys,
accountants, or other professionals
whose firms have derived ten percent or
more of their annual revenue in the
previous two years from clients
involved in securities-related activities
(‘‘Ten-Percent Rule’’); and
• Provide that investment advisers
may not serve as public arbitrators, and
may only serve as non-public arbitrators
if they otherwise qualify as non-public.6
In 2007, FINRA again revised the
definition of ‘‘public arbitrator’’ to:
• Exclude individuals who were
employed by, or who served as an
officer or director of, a company in a
control relationship with a brokerdealer.
• Exclude individuals with a spouse
or immediate family member who was
employed by, or who served as an
officer or director of, a company in a
control relationship with a brokerdealer; and
• Clarify that people registered
through a broker-dealer could not be
public arbitrators even if they are
employed by a non-broker-dealer (such
as a bank).7
Finally, in 2008, FINRA revised the
public arbitrator definition to add a
dollar limit to the Ten-Percent Rule. The
amended definition was designed to
preclude an attorney, accountant, or
other professional from serving as a
public arbitrator if the individual’s firm
derived $50,000 or more in annual
revenue in the past two years from
professional services rendered to certain
industry entities relating to customer
6 See Exchange Act Rel. No. 49573 (April 16,
2004), 69 FR 21871 (Apr. 22, 2004) (File No. SR–
NASD–2003–95) (Order Granting Approval to a
Proposed Rule Change Relating to Arbitrator
Classification and Disclosure in NASD
Arbitrations). The changes were announced in
Notice to Members 04–49 (June 2004).
7 See Act Rel. No. 54607 (Oct. 16, 2006), 71 FR
62026 (Oct. 20, 2006) (File No. SR–NASD–2005–
094) (Order Approving Proposed Rule Change and
Amendment No. 1 Thereto Relating to Amendments
to the Classification of Arbitrators Pursuant to Rule
10308 of the NASD Code of Arbitration Procedure).
The changes were announced in Notice to Members
06–64 (Nov. 2006).
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disputes concerning an investment
account or transaction.8
The proposed rule change is designed
to improve investor confidence in the
neutrality of FINRA’s public arbitrator
roster. In particular, the proposed rule
change would (a) exclude persons
associated with a mutual fund or hedge
fund from serving as public arbitrators
and (b) require individuals to wait for
two years after ending certain
affiliations before they may be permitted
to serve as public arbitrators.
FINRA has indicated that it would
announce the effective date of the
proposed rule change in a Regulatory
Notice to be published no later than 60
days following Commission approval,
and that the effective date would be no
later than 30 days following publication
of the Regulatory Notice announcing
Commission approval.
III. Discussion of Comment Letters
As stated above, the Commission
received 45 comment letters on the
proposed rule change in response to the
Notice. Thirty-eight of those
commenters (represented by 39
comment letters) generally supported
FINRA’s proposal to revise the
definition of ‘‘public arbitrator’’ to
exclude persons associated with a
mutual fund or hedge fund from serving
as public arbitrators.9 Of those
commenters, however, many stated that
while they agreed with the proposed
rule change, they thought FINRA should
exclude additional categories of persons
from the definition of ‘‘public
arbitrator.’’ Moreover, some otherwise
supportive commenters thought that
FINRA should lengthen the proposed
cooling off period.
A. Exclusions
TKELLEY on DSK3SPTVN1PROD with NOTICES
Three commenters suggested that the
definition of ‘‘public arbitrator’’ should
be further narrowed to expressly
exclude from ever acting as a public
arbitrator persons associated with
issuers or sponsors of private
8 See Exchange Act Rel. No. 57492 (Mar. 13,
2008), 73 FR 15025 (Mar. 20, 2008) (File No. SR–
NASD–2007–021) (Order Approving Proposed Rule
Change to Amend the Definition of Public
Arbitrator). The changes were announced in
Regulatory Notice 08–22 (May 2008).
9 See Caruso Letter; Neuman Letter; Layne Letter;
Lipner Letter; Carlson Letter; Aidikoff Letter; Silver
Letter; Uhl Letter; St. John’s Letter; Port Letter;
Catalano Letter; Shewan Letter; Furgison Letter;
Evans and Edmiston Letter; Savage Letter I; Savage
Letter II; Dunlap Letter; Nygaard Letter; Greco
Letter; NASAA Letter; Banks Letter; Ledbetter
Letter; PIABA Letter; Zeck Letter; Sigler Letter;
Goehring Letter; Shepherd Letter; Fogel Letter;
Lewins Letter; Malecki Letter; Sanders Letter; Sonn
Letter; Costello Letter; Estell Letter; Cornell Letter;
Davis Letter; Guiliano Letter; Ostwald Letter; Tobin
Letter.
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placements, publicly offered non-traded
REITs, variable insurance products, and
other investment products.10 These
commenters also suggested that the
definition of ‘‘public arbitrator’’ should
exclude persons who have ever worked
for more than a de minimis time as a
stockbroker or investment advisor, as
well as persons with more than a de
minimis time of affiliation with a
FINRA member firm, an investment
advisory firm, a hedge fund, a mutual
fund, or an issuer, sponsor, marketer, or
seller of securities or investment
products with embedded securities.11
Similarly, two commenters suggested
that anyone who has been licensed to do
business in the securities industry or
depended on the industry for more than
a de minimis amount of his or her
livelihood for any appreciable length of
time should be excluded from the
definition of ‘‘public arbitrator.’’ 12
One commenter suggested that the
definition of ‘‘public arbitrator’’ should
exclude any attorney whose firm has
derived $50,000 or ten percent or more
of its annual revenue in the prior two
years from professional services
rendered to claimants in customer
disputes concerning an investment
account or transaction.13 Another
commenter suggested that individuals
who have been employed by securities
industry trade organizations such as
FINRA should be barred from being
classified as public arbitrators.14
One commenter generally approved of
the proposed rule change but
maintained that, in the context of
customer disputes, FINRA’s current
definition of ‘‘non-public arbitrator’’
must be broadened to include the entire
securities industry, particularly if
FINRA plans to open up its forum to
non-members.15
Finally, another commenter believed
the proposed rule change should
exclude additional categories of
individuals from the definition of
‘‘public arbitrator’’ but ultimately
disapproved of the proposed rule
change on the grounds that it would
continue to permit individuals who
previously worked in and have financial
interests connected to the securities
industry to be classified as public
arbitrators.16 This commenter also
expressed the view that the amended
rule would continue to give FINRA staff
too much discretion in classifying
10 See PIABA Letter; Sanders Letter; Cornell
Letter.
11 Id.
12 See Lewins Letter; Cornell Letter.
13 See FSI Letter.
14 See Davis Letter.
15 See NASAA Letter.
16 See Gard Letter.
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21451
arbitrators. Another commenter
expressed the same concern.17
B. Cooling-Off Period
Fourteen commenters suggested that
FINRA’s proposal to require individuals
to wait for two years after ending certain
affiliations before they may be permitted
to serve as public arbitrators should be
amended to increase the proposed
‘‘cooling off’’ period from two years to
at least five years.18 Five commenters
suggested that the proposed cooling off
period should generally be longer than
two years.19 Three commenters
generally disapproved of the length of
the proposed two-year cooling off
period on the grounds that it would not
serve the interests of investors.20 Two
commenters suggested expanding the
proposed cooling off period from two
years to ten.21 One commenter
suggested that no individual who has
spent ten years or more in the securities
industry should ever be classified as a
public arbitrator.22 Another commenter
suggested that anyone associated with
the industry for twenty or more years
should be prohibited from ever
becoming a public arbitrator.23 Eleven
commenters suggested that no cooling
off period is sufficient and that only
individuals who have never had an
affiliation with the financial services
industry should be eligible to serve as
public arbitrators.24
In its Response Letter, FINRA stated
that the purpose of the proposed rule
change is to respond to investor
representatives’ concerns that certain
arbitrators on the public roster were not
perceived as public because of their
background and experience.
Specifically, FINRA stated that the
proposed rule change would affect
certain persons whose job precludes
them from being classified as a public
arbitrator but does not qualify them as
a non-public arbitrator. In addition,
FINRA stated that the proposed rule
would require persons precluded by
their job from being classified as a
public arbitrator to wait two years
17 See
Gard Letter; Estell Letter.
Caruso Letter; Neuman Letter; Layne Letter;
Harrison Letter; Silver Letter; St. John’s Letter;
Catalano Letter; Zeck Letter; Shepherd Letter;
Malecki Letter; Costello Letter; Estell Letter; Cornell
Letter; Guiliano Letter.
19 See Greco Letter; PIABA Letter; Fogel Letter;
Lewins Letter; Sanders Letter.
20 See Dunlap Letter; Nygaard Letter; Goehring
Letter.
21 See Carlson Letter; Evans and Edmiston Letter.
22 See Uhl Letter.
23 See Harrison Letter.
24 See Lipner Letter; Aidikoff Letter; Silver Letter;
Port Letter; Shewan Letter; Furgison Letter; Evans
and Edmiston Letter; NASAA Letter; Sonn Letter;
Davis Letter; Ostwald Letter.
18 See
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before being eligible to join the public
roster after moving to a job that would
not otherwise disqualify them for
service. FINRA maintained that the
proposed two-year cooling off period
responds to the concerns raised by
investor representatives and would be a
positive step toward enhancing
investors’ perception of fairness in
FINRA’s arbitration forum. FINRA also
stated that it intends to further review,
under the auspices of the National
Arbitration and Mediation Committee,
both the public and non-public
arbitrator definitions with a view
towards clarifying the definitions and
reviewing additional issues such as
those raised in comment letters on the
proposed rule change. Therefore, FINRA
declined to amend the proposed rule
change.
IV. Commission’s Findings
The Commission has carefully
reviewed the proposed rule change, the
comments received, and FINRA’s
Response Letter. Based on its review of
the record, the Commission finds that
the proposed rule change is consistent
with the requirements of the Act and the
rules and regulations thereunder
applicable to a national securities
association.25 In particular, the
Commission finds that the proposed
rule change is consistent with Section
15A(b)(6) of the Act,26 which requires,
among other things, that FINRA rules
must 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.
More specifically, the Commission
finds that the proposed rule change to
exclude persons associated with a
mutual fund or hedge fund from serving
as public arbitrators and require
individuals to wait for two years after
ending certain affiliations before they
may be permitted to serve as public
arbitrators would benefit investors and
other participants in the forum by
improving investor confidence in the
neutrality of FINRA’s public arbitrator
roster. While the Commission
appreciates the suggestions regarding
exclusions from the definition of
‘‘public arbitrator’’ and the proposed
two-year cooling off period, we believe
that FINRA has responded adequately to
comments. We also agree with the
Response Letter’s position that the
proposed rule change should improve
investors’ perception about the fairness
25 In approving this proposed rule change, the
Commission has considered the rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
26 15 U.S.C. 78o–3(b)(6).
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and neutrality of FINRA’s public
arbitrator roster, particularly given the
Response Letter’s representation that
FINRA intends to conduct a
comprehensive review of both the
public and non-public arbitrator
definitions with a view towards further
clarifying the definitions and reviewing
additional issues such as those raised in
comment letters on the proposed rule
change.
For the reasons stated above, the
Commission finds that the proposed
rule change is consistent with the Act
and the rules and regulations
thereunder.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,27 that the
proposed rule change (SR–FINRA–
2013–003) be, and it hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.28
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–08323 Filed 4–9–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–69311; File No. SR–
NYSEArca–2013–36]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Amending Standard
Options Transaction Fees
April 4, 2013.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that, on March
27, 2013, NYSE Arca, Inc. (the
‘‘Exchange’’ or ‘‘NYSE Arca’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared by the selfregulatory organization. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
27 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. 78a.
3 17 CFR 240.19b–4.
28 17
PO 00000
Frm 00115
Fmt 4703
Sfmt 4703
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
Standard Options Transaction Fees. The
text of the proposed rule change is
available on the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization 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 those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of this filing is to modify
the transaction charges for executing
standard options trades on NYSE Arca.
The Exchange proposes to raise the Take
Liquidity Rate in both Penny Pilot
Issues and non-Penny Pilot issues,
while reducing the Post Liquidity credit
for NYSE Arca Market Makers in nonPenny Pilot issues. The Exchange also
proposes to modify the Customer
Monthly Posting Credit Tiers and
Qualifications to provide additional
tiers to incent an increased level of
Customer activity, and create new Tiers
for a similar increase in Customer
activity by providing higher Post
Liquidity credits in non-Penny Pilot
issues.
First, the Exchange proposes to no
longer differentiate the Take Liquidity
rate by contra party, so that a participant
will have a single fee for Taking
Liquidity in Penny Pilot issues. The
Exchange proposes to raise the Take
Liquidity rate for all non-Customers
trading in Penny Pilot issues to $0.47
per contract.
Similarly, the Exchange proposes
raising the Take Liquidity fee for
Electronic Executions in non-Penny
Pilot issues for all participants, with
similar increases but differentiated fees
by participant type. The Take Liquidity
fee for LMMs trading in non-Penny Pilot
issues will be increased from $0.78 to
E:\FR\FM\10APN1.SGM
10APN1
Agencies
[Federal Register Volume 78, Number 69 (Wednesday, April 10, 2013)]
[Notices]
[Pages 21449-21452]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-08323]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-69297; File No. SR-FINRA-2013-003]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving Proposed Rule Change To Amend the
Customer and Industry Codes of Arbitration Procedure To Revise the
Public Arbitrator Definition
April 4, 2013.
I. Introduction
On January 4, 2012, the Financial Industry Regulatory Authority,
Inc. (``FINRA'') filed with the Securities and Exchange Commission
(``SEC'' or ``Commission''), pursuant to Section 19(b)(1) of the
Securities Exchange Act
[[Page 21450]]
of 1934 (``Exchange Act'' or ``Act'') \1\ and Rule 19b-4 thereunder,\2\
a proposed rule change to amend FINRA's Customer and Industry Codes of
Arbitration Procedure (collectively, the ``Codes'') to revise the
definition of ``public arbitrator'' in the Codes. Specifically, the
proposed rule change would (a) exclude persons associated with a mutual
fund or hedge fund from serving as public arbitrators and (b) require
individuals to wait for two years after ending certain affiliations
before they may be permitted to serve as public arbitrators. The
proposed rule change was published for comment in the Federal Register
on January 17, 2013.\3\ The Commission received 45 comment letters on
the proposed rule change,\4\ and a response to comments from FINRA.\5\
This order approves the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Exchange Act Release No. 68632 (Jan. 11, 2013), 78 FR
3925 (Jan. 17, 2013) (``Notice''). The comment period closed on
February 7, 2013.
\4\ See Letter from Steven B. Caruso, Maddox Hargett & Caruso,
dated Jan. 16, 2013 (``Caruso Letter''); letter from David Neuman,
Stoltmann Law Offices, dated Jan. 16, 2013 (``Neuman Letter'');
letter from Richard M. Layne, Law Office of Richard M. Layne, dated
Jan. 28, 2013 (``Layne Letter''); letter from Seth E. Lipner,
Professor of Law, Zickloin School of Business, Baruch College, and
Member, Deutsch & Lipner, dated Jan. 29, 2013 (``Lipner Letter'');
letter from Carl J. Carlson, Tousley Brain Stephens, dated Jan. 29,
2013 (``Carlson Letter''); letter from David Harrison, Law Offices
of David Harrison, dated Jan. 29, 2013 (``Harrison Letter''); letter
from Philip M. Aidikoff, dated Jan. 29, 2013 (``Aidikoff Letter'');
letter from Scott L. Silver, Silver Law Group, dated Jan. 30, 2013
(``Silver Letter''); letter from Robert A. Uhl, Adjunct Professor of
Law, Securities Arbitration and Director, Pepperdine Investor
Advocacy Clinic, and Partner, Aidikoff, Uhl & Bakhtiari, dated Jan.
30, 2013 (``Uhl Letter''); letter from Andrew A. Lipkowitz, Student
Intern, and Christine Lazaro, Acting Director, St. John's University
School of Law Securities Arbitration Clinic, dated Feb. 4, 2013
(``St. John's Letter''); letter from Robert C. Port, Cohen Goldstein
Port & Gottlieb, dated Feb. 5, 2013 (``Port Letter''); letter from
Lisa A. Catalano, dated Feb. 5, 2013 (``Catalano Letter''); letter
from Scott R. Shewan, Pape & Shewan, dated Feb. 6, 2013 (``Shewan
Letter''); letter from Jon C. Furgison, Law Offices of Jon C.
Furgison, dated Feb. 6, 2013 (``Furgison Letter''); letter from
Steven J. Gard, Reznicsek Fraser White & Shaffer, dated Feb. 6, 2013
(``Gard Letter''); letter from Jonathan W. Evans and Michael S.
Edmiston, Jonathan W. Evans & Associates, dated Feb. 6, 2013
(``Evans and Edmiston Letter''); letter from Robert Savage, Visiting
Assistant Clinical Professor, Florida International University
College of Law, dated Feb. 7, 2013 (``Savage Letter I''); letter
from Robert Savage dated Feb. 7, 2013 (``Savage Letter II''); letter
from James A. Dunlap, Jr., James A. Dunlap Jr. & Associates, dated
Feb. 7, 2013 (``Dunlap Letter''); letter from Diane Nygaard, Kenner,
Schmitt & Nygaard, dated Feb. 7, 2013 (``Nygaard Letter''); letter
from W. Scott Greco, Greco & Greco, dated Feb. 7, 2013 (``Greco
Letter''); letter from A. Heath Abshure, NASAA President and
Arkansas Securities Commissioner, dated Feb. 7, 2013 (``NASAA
Letter''); letter from Robert S. Banks, Jr., Banks Law Office, dated
Feb. 7, 2013 (``Banks Letter''); letter from Dale Ledbetter, Esq.,
Ledbetter and Associates, dated Feb. 7, 2013 (``Ledbetter Letter'');
letter from Scott C. Ilgenfritz, President, Public Investors
Arbitration Bar Association, dated Feb. 7, 2013 (``PIABA Letter'');
letter from Elizabeth Zeck, Willoughby & Hoefer, dated Feb. 7, 2013
(``Zeck Letter''); letter from James A. Sigler, dated Feb. 7, 2013
(``Sigler Letter''); letter from Robert W. Goehring, dated Feb. 7,
2013 (``Goehring Letter''); letter from William S. Shepherd,
Shepherd Smith Edwards & Kantas, dated Feb. 7, 2013 (``Shepherd
Letter''); letter from Leonard Steiner, Beverly Hills, California,
dated Feb. 7, 2013 (``Steiner Letter''); letter from Joseph Fogel,
Fogel & Associates, dated Feb. 7, 2013 (``Fogel Letter''); letter
from Richard A. Lewins, dated Feb. 7, 2013 (``Lewins Letter'');
letter from Jenice L. Malecki, Malecki Law, dated Feb. 7, 2013
(``Malecki Letter''); letter from Mark E. Sanders, Halling & Cayo,
dated Feb. 7, 2013 (``Sanders Letter''); letter from Jeffrey Sonn,
Sonn & Erez, dated Feb. 7, 2013 (``Sonn Letter''); letter from
Thomas C. Costello, dated Feb. 7, 2013 (``Costello Letter''); letter
from Barry D. Estell, dated Feb. 7, 2013 (``Estell Letter''); letter
from Royal Lea, dated Feb. 7, 2013 (``Lea Letter''); letter from
Peter Mougey, Levin, Papantonio, Thomas, Mitchell, Rafferty &
Proctor, dated Feb. 7, 2013 (``Mougey Letter''); letter from William
A. Jacobson, Associate Clinical Professor, Cornell Law School, and
Director, Cornell Securities Law Clinic, and Malavika Rao, Cornell
Law School `14, dated Feb. 7, 2013 (``Cornell Letter''); letter from
David T. Bellaire, Executive Vice President and General Counsel,
Financial Services Institute, dated Feb. 7, 2013 (``FSI Letter'');
letter from Theodore M. Davis, dated Feb. 8, 2013 (``Davis
Letter''); letter from Nicholas J. Guiliano, dated Feb. 8, 2013
(``Guiliano Letter''); letter from Mitchell Ostwald, dated Feb. 8,
2013 (``Ostwald Letter''); letter from Charles Michael Tobin, The
Tobin Law Firm, dated Feb 22, 2013 (``Tobin Letter''). Comment
letters are available at https://www.sec.gov.
\5\ See Letter from Margo A. Hassan, Assistant Chief Counsel,
FINRA Dispute Resolution, to Elizabeth M. Murphy, Secretary,
Commission, dated Mar. 11, 2013 (``Response Letter''). The text of
the proposed rule change and a copy of FINRA's Response Letter are
available on FINRA's Web site at https://www.finra.org, at the
principal office of FINRA, and at the Commission's Public Reference
Room. A copy of the Response Letter is also available on the
Commission's Web site at https://www.sec.gov.
---------------------------------------------------------------------------
II. Description of the Proposal
As stated in the Notice, FINRA classifies arbitrators under the
Codes as either ``non-public'' (otherwise known as ``industry''
arbitrators) or ``public.'' Arbitrators are generally considered non-
public if they are affiliated with the securities industry either
because they (1) are currently or were formerly employed in a
securities business; or (2) provide professional services to securities
businesses. Arbitrators are generally considered public if they (1) do
not have any significant affiliation with the securities industry; and
(2) are not related to anyone with a significant affiliation with the
securities industry.
To improve investor confidence in the neutrality of FINRA's public
arbitrator roster, FINRA has amended its arbitrator definitions a
number of times over the years.
In 2004, FINRA amended the definitions of ``public arbitrator'' and
``non-public arbitrator'' to:
Increase from three years to five years the amount of time
necessary after leaving the securities industry to transition from a
non-public to public arbitrator;
Clarify that ``retired'' from the industry includes anyone
who spent a substantial part of his or her career in the industry;
Prohibit anyone who has been associated with the industry
for at least twenty years from ever becoming a public arbitrator,
regardless of how long ago the association ended;
Exclude from the definition of ``public arbitrator''
attorneys, accountants, or other professionals whose firms have derived
ten percent or more of their annual revenue in the previous two years
from clients involved in securities-related activities (``Ten-Percent
Rule''); and
Provide that investment advisers may not serve as public
arbitrators, and may only serve as non-public arbitrators if they
otherwise qualify as non-public.\6\ In 2007, FINRA again revised the
definition of ``public arbitrator'' to:
---------------------------------------------------------------------------
\6\ See Exchange Act Rel. No. 49573 (April 16, 2004), 69 FR
21871 (Apr. 22, 2004) (File No. SR-NASD-2003-95) (Order Granting
Approval to a Proposed Rule Change Relating to Arbitrator
Classification and Disclosure in NASD Arbitrations). The changes
were announced in Notice to Members 04-49 (June 2004).
---------------------------------------------------------------------------
Exclude individuals who were employed by, or who served as
an officer or director of, a company in a control relationship with a
broker-dealer.
Exclude individuals with a spouse or immediate family
member who was employed by, or who served as an officer or director of,
a company in a control relationship with a broker-dealer; and
Clarify that people registered through a broker-dealer
could not be public arbitrators even if they are employed by a non-
broker-dealer (such as a bank).\7\
---------------------------------------------------------------------------
\7\ See Act Rel. No. 54607 (Oct. 16, 2006), 71 FR 62026 (Oct.
20, 2006) (File No. SR-NASD-2005-094) (Order Approving Proposed Rule
Change and Amendment No. 1 Thereto Relating to Amendments to the
Classification of Arbitrators Pursuant to Rule 10308 of the NASD
Code of Arbitration Procedure). The changes were announced in Notice
to Members 06-64 (Nov. 2006).
---------------------------------------------------------------------------
Finally, in 2008, FINRA revised the public arbitrator definition to
add a dollar limit to the Ten-Percent Rule. The amended definition was
designed to preclude an attorney, accountant, or other professional
from serving as a public arbitrator if the individual's firm derived
$50,000 or more in annual revenue in the past two years from
professional services rendered to certain industry entities relating to
customer
[[Page 21451]]
disputes concerning an investment account or transaction.\8\
---------------------------------------------------------------------------
\8\ See Exchange Act Rel. No. 57492 (Mar. 13, 2008), 73 FR 15025
(Mar. 20, 2008) (File No. SR-NASD-2007-021) (Order Approving
Proposed Rule Change to Amend the Definition of Public Arbitrator).
The changes were announced in Regulatory Notice 08-22 (May 2008).
---------------------------------------------------------------------------
The proposed rule change is designed to improve investor confidence
in the neutrality of FINRA's public arbitrator roster. In particular,
the proposed rule change would (a) exclude persons associated with a
mutual fund or hedge fund from serving as public arbitrators and (b)
require individuals to wait for two years after ending certain
affiliations before they may be permitted to serve as public
arbitrators.
FINRA has indicated that it would announce the effective date of
the proposed rule change in a Regulatory Notice to be published no
later than 60 days following Commission approval, and that the
effective date would be no later than 30 days following publication of
the Regulatory Notice announcing Commission approval.
III. Discussion of Comment Letters
As stated above, the Commission received 45 comment letters on the
proposed rule change in response to the Notice. Thirty-eight of those
commenters (represented by 39 comment letters) generally supported
FINRA's proposal to revise the definition of ``public arbitrator'' to
exclude persons associated with a mutual fund or hedge fund from
serving as public arbitrators.\9\ Of those commenters, however, many
stated that while they agreed with the proposed rule change, they
thought FINRA should exclude additional categories of persons from the
definition of ``public arbitrator.'' Moreover, some otherwise
supportive commenters thought that FINRA should lengthen the proposed
cooling off period.
---------------------------------------------------------------------------
\9\ See Caruso Letter; Neuman Letter; Layne Letter; Lipner
Letter; Carlson Letter; Aidikoff Letter; Silver Letter; Uhl Letter;
St. John's Letter; Port Letter; Catalano Letter; Shewan Letter;
Furgison Letter; Evans and Edmiston Letter; Savage Letter I; Savage
Letter II; Dunlap Letter; Nygaard Letter; Greco Letter; NASAA
Letter; Banks Letter; Ledbetter Letter; PIABA Letter; Zeck Letter;
Sigler Letter; Goehring Letter; Shepherd Letter; Fogel Letter;
Lewins Letter; Malecki Letter; Sanders Letter; Sonn Letter; Costello
Letter; Estell Letter; Cornell Letter; Davis Letter; Guiliano
Letter; Ostwald Letter; Tobin Letter.
---------------------------------------------------------------------------
A. Exclusions
Three commenters suggested that the definition of ``public
arbitrator'' should be further narrowed to expressly exclude from ever
acting as a public arbitrator persons associated with issuers or
sponsors of private placements, publicly offered non-traded REITs,
variable insurance products, and other investment products.\10\ These
commenters also suggested that the definition of ``public arbitrator''
should exclude persons who have ever worked for more than a de minimis
time as a stockbroker or investment advisor, as well as persons with
more than a de minimis time of affiliation with a FINRA member firm, an
investment advisory firm, a hedge fund, a mutual fund, or an issuer,
sponsor, marketer, or seller of securities or investment products with
embedded securities.\11\ Similarly, two commenters suggested that
anyone who has been licensed to do business in the securities industry
or depended on the industry for more than a de minimis amount of his or
her livelihood for any appreciable length of time should be excluded
from the definition of ``public arbitrator.'' \12\
---------------------------------------------------------------------------
\10\ See PIABA Letter; Sanders Letter; Cornell Letter.
\11\ Id.
\12\ See Lewins Letter; Cornell Letter.
---------------------------------------------------------------------------
One commenter suggested that the definition of ``public
arbitrator'' should exclude any attorney whose firm has derived $50,000
or ten percent or more of its annual revenue in the prior two years
from professional services rendered to claimants in customer disputes
concerning an investment account or transaction.\13\ Another commenter
suggested that individuals who have been employed by securities
industry trade organizations such as FINRA should be barred from being
classified as public arbitrators.\14\
---------------------------------------------------------------------------
\13\ See FSI Letter.
\14\ See Davis Letter.
---------------------------------------------------------------------------
One commenter generally approved of the proposed rule change but
maintained that, in the context of customer disputes, FINRA's current
definition of ``non-public arbitrator'' must be broadened to include
the entire securities industry, particularly if FINRA plans to open up
its forum to non-members.\15\
---------------------------------------------------------------------------
\15\ See NASAA Letter.
---------------------------------------------------------------------------
Finally, another commenter believed the proposed rule change should
exclude additional categories of individuals from the definition of
``public arbitrator'' but ultimately disapproved of the proposed rule
change on the grounds that it would continue to permit individuals who
previously worked in and have financial interests connected to the
securities industry to be classified as public arbitrators.\16\ This
commenter also expressed the view that the amended rule would continue
to give FINRA staff too much discretion in classifying arbitrators.
Another commenter expressed the same concern.\17\
---------------------------------------------------------------------------
\16\ See Gard Letter.
\17\ See Gard Letter; Estell Letter.
---------------------------------------------------------------------------
B. Cooling-Off Period
Fourteen commenters suggested that FINRA's proposal to require
individuals to wait for two years after ending certain affiliations
before they may be permitted to serve as public arbitrators should be
amended to increase the proposed ``cooling off'' period from two years
to at least five years.\18\ Five commenters suggested that the proposed
cooling off period should generally be longer than two years.\19\ Three
commenters generally disapproved of the length of the proposed two-year
cooling off period on the grounds that it would not serve the interests
of investors.\20\ Two commenters suggested expanding the proposed
cooling off period from two years to ten.\21\ One commenter suggested
that no individual who has spent ten years or more in the securities
industry should ever be classified as a public arbitrator.\22\ Another
commenter suggested that anyone associated with the industry for twenty
or more years should be prohibited from ever becoming a public
arbitrator.\23\ Eleven commenters suggested that no cooling off period
is sufficient and that only individuals who have never had an
affiliation with the financial services industry should be eligible to
serve as public arbitrators.\24\
---------------------------------------------------------------------------
\18\ See Caruso Letter; Neuman Letter; Layne Letter; Harrison
Letter; Silver Letter; St. John's Letter; Catalano Letter; Zeck
Letter; Shepherd Letter; Malecki Letter; Costello Letter; Estell
Letter; Cornell Letter; Guiliano Letter.
\19\ See Greco Letter; PIABA Letter; Fogel Letter; Lewins
Letter; Sanders Letter.
\20\ See Dunlap Letter; Nygaard Letter; Goehring Letter.
\21\ See Carlson Letter; Evans and Edmiston Letter.
\22\ See Uhl Letter.
\23\ See Harrison Letter.
\24\ See Lipner Letter; Aidikoff Letter; Silver Letter; Port
Letter; Shewan Letter; Furgison Letter; Evans and Edmiston Letter;
NASAA Letter; Sonn Letter; Davis Letter; Ostwald Letter.
---------------------------------------------------------------------------
In its Response Letter, FINRA stated that the purpose of the
proposed rule change is to respond to investor representatives'
concerns that certain arbitrators on the public roster were not
perceived as public because of their background and experience.
Specifically, FINRA stated that the proposed rule change would affect
certain persons whose job precludes them from being classified as a
public arbitrator but does not qualify them as a non-public arbitrator.
In addition, FINRA stated that the proposed rule would require persons
precluded by their job from being classified as a public arbitrator to
wait two years
[[Page 21452]]
before being eligible to join the public roster after moving to a job
that would not otherwise disqualify them for service. FINRA maintained
that the proposed two-year cooling off period responds to the concerns
raised by investor representatives and would be a positive step toward
enhancing investors' perception of fairness in FINRA's arbitration
forum. FINRA also stated that it intends to further review, under the
auspices of the National Arbitration and Mediation Committee, both the
public and non-public arbitrator definitions with a view towards
clarifying the definitions and reviewing additional issues such as
those raised in comment letters on the proposed rule change. Therefore,
FINRA declined to amend the proposed rule change.
IV. Commission's Findings
The Commission has carefully reviewed the proposed rule change, the
comments received, and FINRA's Response Letter. Based on its review of
the record, the Commission finds that the proposed rule change is
consistent with the requirements of the Act and the rules and
regulations thereunder applicable to a national securities
association.\25\ In particular, the Commission finds that the proposed
rule change is consistent with Section 15A(b)(6) of the Act,\26\ which
requires, among other things, that FINRA rules must 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.
---------------------------------------------------------------------------
\25\ In approving this proposed rule change, the Commission has
considered the rule's impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
\26\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
More specifically, the Commission finds that the proposed rule
change to exclude persons associated with a mutual fund or hedge fund
from serving as public arbitrators and require individuals to wait for
two years after ending certain affiliations before they may be
permitted to serve as public arbitrators would benefit investors and
other participants in the forum by improving investor confidence in the
neutrality of FINRA's public arbitrator roster. While the Commission
appreciates the suggestions regarding exclusions from the definition of
``public arbitrator'' and the proposed two-year cooling off period, we
believe that FINRA has responded adequately to comments. We also agree
with the Response Letter's position that the proposed rule change
should improve investors' perception about the fairness and neutrality
of FINRA's public arbitrator roster, particularly given the Response
Letter's representation that FINRA intends to conduct a comprehensive
review of both the public and non-public arbitrator definitions with a
view towards further clarifying the definitions and reviewing
additional issues such as those raised in comment letters on the
proposed rule change.
For the reasons stated above, the Commission finds that the
proposed rule change is consistent with the Act and the rules and
regulations thereunder.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\27\ that the proposed rule change (SR-FINRA-2013-003) be, and it
hereby is, approved.
---------------------------------------------------------------------------
\27\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\28\
---------------------------------------------------------------------------
\28\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2013-08323 Filed 4-9-13; 8:45 am]
BILLING CODE 8011-01-P