Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving Proposed Rule Change To Amend Rule 12403 (Cases With Three Arbitrators) of the Code of Arbitration Procedure for Customer Disputes Relating to the Panel Selection Process in Arbitration, 64564-64566 [2016-22535]
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64564
Federal Register / Vol. 81, No. 182 / Tuesday, September 20, 2016 / Notices
SECURITIES AND EXCHANGE
COMMISSION
II. Description of the Proposed Rule
Change
[Release No. 34–78836; File No. SR–FINRA–
2016–022]
FINRA allows parties to participate in
selecting the arbitrators who serve on
their cases. Parties select their
arbitration panel from computer
generated lists of arbitrators that FINRA
sends them. Under current FINRA Rule
12403(a), in customer cases with three
arbitrators,7 FINRA sends the parties
three lists: a list of ten (10) chairqualified public arbitrators, a list of ten
(10) public arbitrators, and a list of ten
(10) non-public arbitrators.8 The parties
select their panel through a process of
striking and ranking the arbitrators on
the lists.9 Under current Rule
12403(c)(2), each party is allowed to
strike up to four (4) arbitrators on the
chair-qualified public list and four (4)
arbitrators on the public list. At least six
(6) names must remain on each list.
However, Rule 12403(c)(1) provides for
unlimited strikes on the non-public list
so that any party may select a panel of
all public arbitrators in a customer
case.10
Under the Customer Code, when
parties collectively strike all of the nonpublic arbitrators from the list, FINRA
fills all three panel seats from the two
10-person lists of public arbitrators.11
When parties collectively strike all of
the arbitrators appearing on the nonpublic list, FINRA returns to the public
list to select the next highest ranked
available arbitrator to fill the seat.12 If
no public arbitrators remain available to
fill the vacancy, FINRA returns to the
chair-qualified public list to select the
next highest ranked public chair.13 In
doing so, there is a likelihood that
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change To Amend Rule
12403 (Cases With Three Arbitrators)
of the Code of Arbitration Procedure
for Customer Disputes Relating to the
Panel Selection Process in Arbitration
September 14, 2016.
I. Introduction
On July 1, 2016, Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’)
filed with the Securities and Exchange
Commission (‘‘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 FINRA Rule 12403
(Cases with Three Arbitrators) of the
Code of Arbitration Procedure for
Customer Disputes (‘‘Customer Code’’)
relating to the panel selection process in
arbitration. The proposal was published
for comment in the Federal Register on
July 15, 2016.3 The comment period
closed on August 5, 2016. The
Commission received eight (8) comment
letters on the proposal.4 On August 12,
2016, FINRA extended the time, until
October 13, 2016, for Commission
action on the proposal.5 FINRA
responded to the comment letters on
August 18, 2016.6 This order approves
the proposed rule change.
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 78279
(July 11, 2016), 81 FR 46139 (July 15, 2016) (File
No. SR–FINRA–2016–022) (‘‘Notice’’).
4 See Letter from Steven B. Caruso, Maddox
Hargett & Caruso, P.C., dated July 14, 2016 (‘‘Caruso
Letter’’); Letter from Julius Z. Frager, J.D., M.B.A.,
dated July 24, 2016 (‘‘Frager Letter’’); Letter from
Ryan K. Bakhtiari, Aidikoff, Uhl & Bakhtiari, dated
July 26, 2016 (‘‘Bakhtiari Letter’’); Letter from Philip
M. Aidikoff, Aidikoff, Uhl & Bakhtiari, dated July
27, 2016 (‘‘Aidikoff Letter’’); Letter from Hugh D.
Berkson, President, Public Investors Arbitration Bar
Association (‘‘PIABA’’), dated August 4, 2016
(‘‘PIABA Letter’’); Letter from David T. Bellaire,
Esq., Executive Vice President and General Counsel,
Financial Services Institute (‘‘FSI’’), dated August 4,
2016 (‘‘FSI Letter’’); Letter from Tyler M. Fiorillo,
Student Intern, and Elissa Germaine, Supervising
Attorney, Pace Investor Rights Clinic (‘‘PIRC’’),
dated August 5, 2016 (‘‘PIRC Letter’’), and Letter
from Glenn S. Gitomer, Chair of Litigation Practice
Group, McCausland Keen Buckman, dated August
5, 2016 (‘‘Gitomer Letter’’).
5 See Letter from Margo A. Hassan, Associate
Chief Counsel, Office of Dispute Resolution, FINRA,
to Lourdes Gonzalez, Assistant Chief Counsel—
Sales Practices, Division of Trading and Markets,
Securities and Exchange Commission, dated August
12, 2016.
6 See Letter from Margo A. Hassan, Associate
Chief Counsel, Office of Dispute Resolution, FINRA,
sradovich on DSK3GMQ082PROD with NOTICES
2 17
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17:13 Sep 19, 2016
Jkt 238001
to Brent J. Fields, Secretary, Securities and
Exchange Commission, dated August 18, 2016
(‘‘FINRA Response Letter’’).
7 See FINRA Rule 12401, which provides that if
the amount of a claim is more than $100,000,
exclusive of interest and expenses, or is
unspecified, or if the claim does not request money
damages, the panel will consist of three arbitrators,
unless the parties agree in writing to one arbitrator.
8 Public arbitrators do not have an affiliation with
the financial industry. The non-public arbitrator
roster includes individuals who: (1) Are employed
in the financial industry; (2) provide services to
industry entities and their employees; or (3) devote
a significant part of their business to representing
or providing services to parties in disputes
concerning investments or employment
relationships. See Notice, 81 FR at 46139; see also
Securities Exchange Act Release No 74383 (Feb. 26,
2014), 80 FR 11695 (Mar. 4, 2014) (File No. SR–
FINRA–2014–028) (Self-Regulatory Organizations;
Financial Industry Regulatory Authority, Inc.; Order
Approving a Proposed Rule Change Relating to
Revisions to the Definitions of Non-Public
Arbitrator and Public Arbitrator).
9 See FINRA Rule 12403(c).
10 See Notice, 81 FR at 46139.
11 See FINRA Rule 12403(d), (e).
12 See FINRA Rule 12403(e).
13 Id.
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Frm 00137
Fmt 4703
Sfmt 4703
FINRA will appoint an arbitrator who
the parties accepted, but ranked lower
on the public or chair-qualified public
lists.14 FINRA believes that where
parties collectively strike all the nonpublic arbitrators (i.e., where they desire
an all-public panel), the parties should
have greater choice of public
arbitrators.15
Consequently, FINRA is proposing to
amend Rule 12403(a)(1) to increase the
number of arbitrators on the public
arbitrator list FINRA sends the parties
from ten (10) to fifteen (15). FINRA
believes this amendment would provide
the parties with greater choice of public
arbitrators during the panel selection
process.16
FINRA is also proposing to amend
Rule 12403(c)(2) to increase the number
of strikes to the public arbitrator list
from four (4) to six (6), so that the
proportion of strikes is the same under
the amended rule as it is under the
current rule. FINRA believes that
increasing the number of strikes the
parties can make to the newly increased
public list will improve the likelihood
that the parties’ preferred arbitrators
will be appointed to the panel.17
III. Summary of Comments and
FINRA’s Response
The Commission received eight (8)
comment letters on the proposed rule
change,18 and a response letter from
FINRA.19 As discussed in more detail
below, six (6) commenters expressed
support for the proposal as filed,20 one
(1) commenter generally supported the
proposal while expressing additional
concerns,21 and one (1) commenter
proposed an alternative approach for
panel selection in customer cases.22 The
sections below outline the support,
concerns raised and alternatives
proposed by commenters, as well as
FINRA’s response.
Support for the Proposal
Six (6) commenters supported the
proposed increase in the number of
arbitrators on the public arbitrator list
from ten (10) to fifteen (15), as well as
the proportional increase from four (4)
to six (6) strikes that parties may make
to the public arbitrator list. These
commenters stated, among other things,
that the proposal would provide parties
14 See
Notice, 81 FR at 46139.
15 Id.
16 Id.
at 46139–40.
at 46140
18 See supra note 4.
19 See supra note 6.
20 See Caruso Letter; Bakhtiari Letter; Aidikoff
Letter; FSI Letter; PIRC Letter; Gitomer Letter.
21 See PIABA Letter.
22 See Frager Letter.
17 Id.
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Federal Register / Vol. 81, No. 182 / Tuesday, September 20, 2016 / Notices
with a greater choice in the arbitrator
selection process, increasing the
likelihood that an arbitrator preferred by
both parties would be appointed to the
panel.23 Consequently, these
commenters generally believe that the
proposed rule change ‘‘is a fair,
equitable and reasonable approach[,]’’ 24
‘‘is an important step towards protecting
the investing public[,]’’ 25 ‘‘will greatly
enhance the fairness of the forum to
both the investing public and FINRA
members[,]’’ 26 ‘‘results in more
equitable arbitration proceedings,’’ 27
and ‘‘benefits all parties, with a
particularly positive impact on modestmeans investors.’’ 28
Additional Concerns
One (1) commenter generally
supported the proposal, but also
expressed concerns about other aspects
of the arbitrator selection process.29
Specifically, this commenter believes
that FINRA should address the shortage
of local arbitrators by intensifying its
efforts to recruit suitable local
individuals to serve as public and
chair-qualified arbitrators, particularly
in locations with shallow arbitrator
pools.30 In addition, this commenter
recommends that FINRA increase the
transparency of its list-selection
process.31
In response, FINRA stated that it
believes this commenter’s suggestions
are outside the scope of the proposal.32
Therefore, FINRA did not address them
in its response.33
sradovich on DSK3GMQ082PROD with NOTICES
Alternative Proposal
One (1) commenter did not directly
oppose the proposal but did recommend
that FINRA adopt an alternative
approach for panel selection in
customer cases. Among other things,
this commenter suggested that FINRA
maintain the three current ten-person
lists of non-public, chair-public and
public arbitrators. Each party could
strike all of the names on the non-public
list, and four names on each public list.
Each party would then submit to FINRA
one combined list of ranked chair23 See Caruso Letter, Aidikoff Letter, FSI Letter,
and PIRC Letter; see also Bakhtiari Letter, Gitmore
Letter and PIABA Letter (stating that ‘‘having the
ability to consider more candidates helps both
claimants and respondents.’’
24 See Caruso Letter; see also Aidikoff Letter and
FSI Letter.
25 See Bakhtiari Letter.
26 See Gitomer Letter.
27 See FSI Letter.
28 See PIRC Letter.
29 See PIABA Letter.
30 Id.
31 Id.
32 See FINRA Response Letter.
33 Id.
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17:13 Sep 19, 2016
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public and public arbitrators. FINRA
would appoint the highest ranked chairqualified arbitrator as chair. If the
parties collectively struck all of the nonpublic arbitrators, FINRA would then
appoint two public arbitrators from
those remaining on the parties’
combined list (regardless of whether
they are chair-qualified).34 The
commenter believes that this proposal
would benefit parties to an arbitration
because, among other things, they
would not need to vet the proposed
additional five public arbitrators.35
In its response, FINRA stated that
forum users generally prefer greater
choice during the arbitrator selection
process.36 FINRA also stated that unlike
the commenter’s suggestion, the
proposed rule change would provide
parties greater choice by adding five (5)
public arbitrators to the panel selection
process.37 In addition, FINRA believes
that the commenter’s approach to panel
selection would be complex and
difficult for parties to navigate,
especially parties or party
representatives that do not use the
forum on a regular basis.38 Accordingly,
FINRA did not amend the proposal to
reflect the commenter’s recommended
amendments.
IV. Discussion and Commission
Findings
The Commission has carefully
considered the proposal, the comments
received, and FINRA’s response to the
comments. 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.39 In particular, the
Commission finds that the proposed
rule change is consistent with Section
15A(b)(6) of the Act,40 which requires,
among other things, that FINRA’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. FINRA
believes, and the Commission agrees,
that the proposed rule change would
34 See Frager Letter; see also FINRA Response
Letter (describing the commenter’s proposal).
35 See Frager Letter.
36 See FINRA Response Letter (stating that forum
users have indicated that ‘‘the benefits of additional
choice outweigh the cost of vetting additional
arbitrators’’).
37 See FINRA Response Letter.
38 Id.
39 In approving the proposed rule change, the
Commission has also considered its impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
40 15 U.S.C. 78o–3(b)(6).
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Fmt 4703
Sfmt 4703
64565
protect investors and the public interest
by providing greater choice for parties
in customer cases with three arbitrators
during the panel selection process.
As discussed above, the proposal
would amend Rule 12403(a)(1) to
increase the number of arbitrators on the
public arbitrator list that FINRA sends
the parties from ten (10) to fifteen (15).41
It would also amend Rule 12403(c)(2) to
increase the number of strikes to the
public arbitrator list from four (4) to six
(6), so that the proportion of strikes is
the same under the amended rule as it
is under the current rule.42
The Commission has considered the
eight (8) comment letters received on
the proposed rule change,43 along with
FINRA’s response to the comments.44
The Commission notes that most of the
commenters support the proposed rule
change, expressing the belief that the
proposal would increase parties’ choice
among public arbitrators during the
arbitrator selection process,45 and
thereby benefit parties in arbitration and
enhance the fairness of the forum.46
However, the Commission also
recognizes commenters’ concerns and
suggestions.47
While the Commission acknowledges
that FINRA’s proposed amendments to
Rule 12403 might result in an increased
burden in vetting additional arbitrators,
the Commission agrees with FINRA that
parties would benefit from having
greater choice in selecting public
arbitrators, and that the benefits of this
greater choice would outweigh the cost
of additional vetting.48 The Commission
additionally agrees with FINRA’s
assessment that the proposed alternative
arbitrator selection process suggested by
one commenter 49 would not provide
the benefit of greater choice and would
unnecessarily complicate the arbitrator
selection process.50
In addition, the Commission agrees
with FINRA’s assessment that the
‘‘shortage of local arbitrators’’ and the
transparency of FINRA’s arbitrator listselection process 51 are outside the
scope of the proposal.52
For the reasons stated above, the
Commission finds that the proposed
rule change is consistent with the Act
41 See
Notice, 81 FR at 46139.
42 Id.
43 See
supra note 4.
supra note 6.
45 See supra note 23.
46 See supra notes 24–28.
47 See PIABA Letter and Frager Letter.
48 See FINRA Response Letter.
49 See Frager Letter.
50 See FINRA Response Letter.
51 See PIABA Letter.
52 See FINRA Response Letter.
44 See
E:\FR\FM\20SEN1.SGM
20SEN1
64566
Federal Register / Vol. 81, No. 182 / Tuesday, September 20, 2016 / Notices
and the rules and regulations
thereunder.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,53 that the
proposed rule change (SR–FINRA–
2016–022) be, and hereby is, approved.
For the Commission, by the Division
of Trading and Markets, pursuant to
delegated authority.54
Robert W. Errett,
Deputy Secretary.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change.
[FR Doc. 2016–22535 Filed 9–19–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–78838; File No. SR–BX–
2016–050]
Self-Regulatory Organizations;
NASDAQ BX, Inc.; Notice of Filing of
Proposed Rule Change To Describe
Changes to System Functionality
Necessary To Implement the Tick Size
Pilot Program
September 14, 2016.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on
September 7, 2016, NASDAQ BX, Inc.
(‘‘BX’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III, below, which Items have been
prepared by the Exchange. 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 Exchange proposes to adopt
paragraph (d) to Exchange Rule 4770 to
describe changes to System 3
53 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 The term ‘‘System’’ is defined as the automated
system for order execution and trade reporting
owned and operated by the Exchange. The System
comprises: (1) A montage for Quotes and Orders,
referred to herein as the ‘‘Exchange Book,’’ that
collects and ranks all Quotes and Orders submitted
by Participants; (2) an Order execution service that
enables Participants to automatically execute
transactions in System Securities; and provides
Participants with sufficient monitoring and
updating capability to participate in an automated
execution environment; (3) a trade reporting service
that submits ‘‘locked-in’’ trades for clearing to a
registered clearing agency for clearance and
settlement; transmits last-sale reports of
transactions automatically to the national trade
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54 17
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17:13 Sep 19, 2016
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functionality necessary to implement
the Regulation NMS Plan to Implement
a Tick Size Pilot Program (‘‘Plan’’).4 The
Exchange is also proposing amendments
to Rule 4770(a) and (c) to clarify how
the Trade-at exception may be satisfied.
The text of the proposed rule change
is available on the Exchange’s Web site
at https://nasdaqbx.cchwallstreet.com/,
at the principal office of the Exchange,
and at the Commission’s Public
Reference Room.
In its filing with the Commission, the
Exchange 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 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 aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
Background
On August 25, 2014, NYSE Group,
Inc., on behalf of Bats BZX Exchange,
Inc. (f/k/a BATS Exchange, Inc.), Bats
BYX Exchange, Inc. (f/k/a BATS YExchange, Inc.), Chicago Stock
Exchange, Inc., EDGA Exchange, Inc.,
EDGX Exchange, Inc., the Exchange,
Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’), The
NASDAQ Stock Market LLC, New York
Stock Exchange LLC, NASDAQ PHLX
LLC, NYSE Arca, Inc., and the NYSE
MKT LLC, (collectively ‘‘Participants’’),
filed the Plan with the Commission
pursuant to Section 11A of the Act 5 and
Rule 608 of Regulation NMS
reporting system, if required, for dissemination to
the public and industry; and provides participants
with monitoring and risk management capabilities
to facilitate participation in a ‘‘locked-in’’ trading
environment; and (4) data feeds that can be used to
display with attribution to Participants’ MPIDs all
Quotes and displayed Orders on both the bid and
offer side of the market for all price levels then
within the NASDAQ OMX BX Equities Market, and
that disseminate such additional information about
Quotes, Orders, and transactions within the System
as shall be reflected in the Exchange Rules. See
Rule 4701(a).
4 See Securities Exchange Act Release No. 74892
(May 6, 2015), 80 FR 27513 (May 13, 2015)
(‘‘Approval Order’’).
5 15 U.S.C. 78k–1.
PO 00000
Frm 00139
Fmt 4703
Sfmt 4703
thereunder.6 The Participants filed the
Plan to comply with an order issued by
the Commission on June 24, 2014 (the
‘‘June 2014 Order’’).7 The Plan 8 was
published for comment in the Federal
Register on November 7, 2014,9 and
approved by the Commission, as
modified, on May 6, 2015.10
The Plan is designed to allow the
Commission, market participants, and
the public to study and assess the
impact of increment conventions on the
liquidity and trading of the common
stocks of small capitalization
companies. The Commission plans to
use the Tick Size Pilot Program to assess
whether wider tick sizes enhance the
market quality of Pilot Securities for the
benefit of issuers and investors. Each
Participant is required to comply with,
and to enforce compliance by its
members, as applicable, with the
provisions of the Plan.
On October 9, 2015, the Operating
Committee approved the Exchange’s
proposed rules as model Participant
rules that would require compliance by
a Participant’s members with the
provisions of the Plan, as applicable,
and would establish written policies
and procedures reasonably designed to
comply with applicable quoting and
trading requirements specified in the
Plan.11 As described more fully below,
the proposed rules would require
members to comply with the Plan and
provide for the widening of quoting and
trading increments for Pilot Securities,
consistent with the Plan.
The Plan will include stocks of
companies with $3 billion or less in
market capitalization, an average daily
trading volume of one million shares or
less, and a volume weighted average
price of at least $2.00 for every trading
day. The Plan will consist of a control
6 See Letter from Brendon J. Weiss, Vice
President, Intercontinental Exchange, Inc., to
Secretary, Commission, dated August 25, 2014.
7 See Securities Exchange Act Release No. 72460
(June 24, 2014), 79 FR 36840 (June 30, 2014).
8 Unless otherwise specified, capitalized terms
used in this rule filing are based on the defined
terms of the Plan.
9 See Securities and Exchange Act Release No.
73511 (November 3, 2014), 79 FR 66423 (File No.
4–657) (Tick Plan Filing).
10 See Tick Plan Approval Order, supra note 4.
See also Securities Exchange Act Release No. 77277
(March 3, 2016), 81 FR 12162 (March 8, 2016) (File
No. 4–657), which amended the Plan to add
National Stock Exchange, Inc. as a Participant.
11 The Operating Committee is required under
Section III(C)(2) of the Plan to ‘‘monitor the
procedures established pursuant to the Plan and
advise Participants with respect to any deficiencies,
problems, or recommendations as the Operating
Committee may deem appropriate.’’ The Operating
Committee is also required to ‘‘establish
specifications and procedures for the
implementation and operation of the Plan that are
consistent with the provisions of the Plan.’’
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Agencies
[Federal Register Volume 81, Number 182 (Tuesday, September 20, 2016)]
[Notices]
[Pages 64564-64566]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-22535]
[[Page 64564]]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-78836; File No. SR-FINRA-2016-022]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving Proposed Rule Change To Amend Rule
12403 (Cases With Three Arbitrators) of the Code of Arbitration
Procedure for Customer Disputes Relating to the Panel Selection Process
in Arbitration
September 14, 2016.
I. Introduction
On July 1, 2016, Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission
(``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 FINRA Rule 12403 (Cases with Three
Arbitrators) of the Code of Arbitration Procedure for Customer Disputes
(``Customer Code'') relating to the panel selection process in
arbitration. The proposal was published for comment in the Federal
Register on July 15, 2016.\3\ The comment period closed on August 5,
2016. The Commission received eight (8) comment letters on the
proposal.\4\ On August 12, 2016, FINRA extended the time, until October
13, 2016, for Commission action on the proposal.\5\ FINRA responded to
the comment letters on August 18, 2016.\6\ This order approves the
proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 78279 (July 11,
2016), 81 FR 46139 (July 15, 2016) (File No. SR-FINRA-2016-022)
(``Notice'').
\4\ See Letter from Steven B. Caruso, Maddox Hargett & Caruso,
P.C., dated July 14, 2016 (``Caruso Letter''); Letter from Julius Z.
Frager, J.D., M.B.A., dated July 24, 2016 (``Frager Letter'');
Letter from Ryan K. Bakhtiari, Aidikoff, Uhl & Bakhtiari, dated July
26, 2016 (``Bakhtiari Letter''); Letter from Philip M. Aidikoff,
Aidikoff, Uhl & Bakhtiari, dated July 27, 2016 (``Aidikoff
Letter''); Letter from Hugh D. Berkson, President, Public Investors
Arbitration Bar Association (``PIABA''), dated August 4, 2016
(``PIABA Letter''); Letter from David T. Bellaire, Esq., Executive
Vice President and General Counsel, Financial Services Institute
(``FSI''), dated August 4, 2016 (``FSI Letter''); Letter from Tyler
M. Fiorillo, Student Intern, and Elissa Germaine, Supervising
Attorney, Pace Investor Rights Clinic (``PIRC''), dated August 5,
2016 (``PIRC Letter''), and Letter from Glenn S. Gitomer, Chair of
Litigation Practice Group, McCausland Keen Buckman, dated August 5,
2016 (``Gitomer Letter'').
\5\ See Letter from Margo A. Hassan, Associate Chief Counsel,
Office of Dispute Resolution, FINRA, to Lourdes Gonzalez, Assistant
Chief Counsel--Sales Practices, Division of Trading and Markets,
Securities and Exchange Commission, dated August 12, 2016.
\6\ See Letter from Margo A. Hassan, Associate Chief Counsel,
Office of Dispute Resolution, FINRA, to Brent J. Fields, Secretary,
Securities and Exchange Commission, dated August 18, 2016 (``FINRA
Response Letter'').
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
FINRA allows parties to participate in selecting the arbitrators
who serve on their cases. Parties select their arbitration panel from
computer generated lists of arbitrators that FINRA sends them. Under
current FINRA Rule 12403(a), in customer cases with three
arbitrators,\7\ FINRA sends the parties three lists: a list of ten (10)
chair-qualified public arbitrators, a list of ten (10) public
arbitrators, and a list of ten (10) non-public arbitrators.\8\ The
parties select their panel through a process of striking and ranking
the arbitrators on the lists.\9\ Under current Rule 12403(c)(2), each
party is allowed to strike up to four (4) arbitrators on the chair-
qualified public list and four (4) arbitrators on the public list. At
least six (6) names must remain on each list. However, Rule 12403(c)(1)
provides for unlimited strikes on the non-public list so that any party
may select a panel of all public arbitrators in a customer case.\10\
---------------------------------------------------------------------------
\7\ See FINRA Rule 12401, which provides that if the amount of a
claim is more than $100,000, exclusive of interest and expenses, or
is unspecified, or if the claim does not request money damages, the
panel will consist of three arbitrators, unless the parties agree in
writing to one arbitrator.
\8\ Public arbitrators do not have an affiliation with the
financial industry. The non-public arbitrator roster includes
individuals who: (1) Are employed in the financial industry; (2)
provide services to industry entities and their employees; or (3)
devote a significant part of their business to representing or
providing services to parties in disputes concerning investments or
employment relationships. See Notice, 81 FR at 46139; see also
Securities Exchange Act Release No 74383 (Feb. 26, 2014), 80 FR
11695 (Mar. 4, 2014) (File No. SR-FINRA-2014-028) (Self-Regulatory
Organizations; Financial Industry Regulatory Authority, Inc.; Order
Approving a Proposed Rule Change Relating to Revisions to the
Definitions of Non-Public Arbitrator and Public Arbitrator).
\9\ See FINRA Rule 12403(c).
\10\ See Notice, 81 FR at 46139.
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Under the Customer Code, when parties collectively strike all of
the non-public arbitrators from the list, FINRA fills all three panel
seats from the two 10-person lists of public arbitrators.\11\ When
parties collectively strike all of the arbitrators appearing on the
non-public list, FINRA returns to the public list to select the next
highest ranked available arbitrator to fill the seat.\12\ If no public
arbitrators remain available to fill the vacancy, FINRA returns to the
chair-qualified public list to select the next highest ranked public
chair.\13\ In doing so, there is a likelihood that FINRA will appoint
an arbitrator who the parties accepted, but ranked lower on the public
or chair-qualified public lists.\14\ FINRA believes that where parties
collectively strike all the non-public arbitrators (i.e., where they
desire an all-public panel), the parties should have greater choice of
public arbitrators.\15\
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\11\ See FINRA Rule 12403(d), (e).
\12\ See FINRA Rule 12403(e).
\13\ Id.
\14\ See Notice, 81 FR at 46139.
\15\ Id.
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Consequently, FINRA is proposing to amend Rule 12403(a)(1) to
increase the number of arbitrators on the public arbitrator list FINRA
sends the parties from ten (10) to fifteen (15). FINRA believes this
amendment would provide the parties with greater choice of public
arbitrators during the panel selection process.\16\
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\16\ Id. at 46139-40.
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FINRA is also proposing to amend Rule 12403(c)(2) to increase the
number of strikes to the public arbitrator list from four (4) to six
(6), so that the proportion of strikes is the same under the amended
rule as it is under the current rule. FINRA believes that increasing
the number of strikes the parties can make to the newly increased
public list will improve the likelihood that the parties' preferred
arbitrators will be appointed to the panel.\17\
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\17\ Id. at 46140
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III. Summary of Comments and FINRA's Response
The Commission received eight (8) comment letters on the proposed
rule change,\18\ and a response letter from FINRA.\19\ As discussed in
more detail below, six (6) commenters expressed support for the
proposal as filed,\20\ one (1) commenter generally supported the
proposal while expressing additional concerns,\21\ and one (1)
commenter proposed an alternative approach for panel selection in
customer cases.\22\ The sections below outline the support, concerns
raised and alternatives proposed by commenters, as well as FINRA's
response.
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\18\ See supra note 4.
\19\ See supra note 6.
\20\ See Caruso Letter; Bakhtiari Letter; Aidikoff Letter; FSI
Letter; PIRC Letter; Gitomer Letter.
\21\ See PIABA Letter.
\22\ See Frager Letter.
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Support for the Proposal
Six (6) commenters supported the proposed increase in the number of
arbitrators on the public arbitrator list from ten (10) to fifteen
(15), as well as the proportional increase from four (4) to six (6)
strikes that parties may make to the public arbitrator list. These
commenters stated, among other things, that the proposal would provide
parties
[[Page 64565]]
with a greater choice in the arbitrator selection process, increasing
the likelihood that an arbitrator preferred by both parties would be
appointed to the panel.\23\ Consequently, these commenters generally
believe that the proposed rule change ``is a fair, equitable and
reasonable approach[,]'' \24\ ``is an important step towards protecting
the investing public[,]'' \25\ ``will greatly enhance the fairness of
the forum to both the investing public and FINRA members[,]'' \26\
``results in more equitable arbitration proceedings,'' \27\ and
``benefits all parties, with a particularly positive impact on modest-
means investors.'' \28\
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\23\ See Caruso Letter, Aidikoff Letter, FSI Letter, and PIRC
Letter; see also Bakhtiari Letter, Gitmore Letter and PIABA Letter
(stating that ``having the ability to consider more candidates helps
both claimants and respondents.''
\24\ See Caruso Letter; see also Aidikoff Letter and FSI Letter.
\25\ See Bakhtiari Letter.
\26\ See Gitomer Letter.
\27\ See FSI Letter.
\28\ See PIRC Letter.
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Additional Concerns
One (1) commenter generally supported the proposal, but also
expressed concerns about other aspects of the arbitrator selection
process.\29\ Specifically, this commenter believes that FINRA should
address the shortage of local arbitrators by intensifying its efforts
to recruit suitable local individuals to serve as public and
chair[hyphen]qualified arbitrators, particularly in locations with
shallow arbitrator pools.\30\ In addition, this commenter recommends
that FINRA increase the transparency of its list-selection process.\31\
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\29\ See PIABA Letter.
\30\ Id.
\31\ Id.
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In response, FINRA stated that it believes this commenter's
suggestions are outside the scope of the proposal.\32\ Therefore, FINRA
did not address them in its response.\33\
---------------------------------------------------------------------------
\32\ See FINRA Response Letter.
\33\ Id.
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Alternative Proposal
One (1) commenter did not directly oppose the proposal but did
recommend that FINRA adopt an alternative approach for panel selection
in customer cases. Among other things, this commenter suggested that
FINRA maintain the three current ten-person lists of non-public, chair-
public and public arbitrators. Each party could strike all of the names
on the non-public list, and four names on each public list. Each party
would then submit to FINRA one combined list of ranked chair-public and
public arbitrators. FINRA would appoint the highest ranked chair-
qualified arbitrator as chair. If the parties collectively struck all
of the non-public arbitrators, FINRA would then appoint two public
arbitrators from those remaining on the parties' combined list
(regardless of whether they are chair-qualified).\34\ The commenter
believes that this proposal would benefit parties to an arbitration
because, among other things, they would not need to vet the proposed
additional five public arbitrators.\35\
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\34\ See Frager Letter; see also FINRA Response Letter
(describing the commenter's proposal).
\35\ See Frager Letter.
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In its response, FINRA stated that forum users generally prefer
greater choice during the arbitrator selection process.\36\ FINRA also
stated that unlike the commenter's suggestion, the proposed rule change
would provide parties greater choice by adding five (5) public
arbitrators to the panel selection process.\37\ In addition, FINRA
believes that the commenter's approach to panel selection would be
complex and difficult for parties to navigate, especially parties or
party representatives that do not use the forum on a regular basis.\38\
Accordingly, FINRA did not amend the proposal to reflect the
commenter's recommended amendments.
---------------------------------------------------------------------------
\36\ See FINRA Response Letter (stating that forum users have
indicated that ``the benefits of additional choice outweigh the cost
of vetting additional arbitrators'').
\37\ See FINRA Response Letter.
\38\ Id.
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IV. Discussion and Commission Findings
The Commission has carefully considered the proposal, the comments
received, and FINRA's response to the comments. 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.\39\ In particular, the Commission finds that the proposed
rule change is consistent with Section 15A(b)(6) of the Act,\40\ which
requires, among other things, that FINRA'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. FINRA believes, and the Commission agrees,
that the proposed rule change would protect investors and the public
interest by providing greater choice for parties in customer cases with
three arbitrators during the panel selection process.
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\39\ In approving the proposed rule change, the Commission has
also considered its impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
\40\ 15 U.S.C. 78o-3(b)(6).
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As discussed above, the proposal would amend Rule 12403(a)(1) to
increase the number of arbitrators on the public arbitrator list that
FINRA sends the parties from ten (10) to fifteen (15).\41\ It would
also amend Rule 12403(c)(2) to increase the number of strikes to the
public arbitrator list from four (4) to six (6), so that the proportion
of strikes is the same under the amended rule as it is under the
current rule.\42\
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\41\ See Notice, 81 FR at 46139.
\42\ Id.
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The Commission has considered the eight (8) comment letters
received on the proposed rule change,\43\ along with FINRA's response
to the comments.\44\ The Commission notes that most of the commenters
support the proposed rule change, expressing the belief that the
proposal would increase parties' choice among public arbitrators during
the arbitrator selection process,\45\ and thereby benefit parties in
arbitration and enhance the fairness of the forum.\46\ However, the
Commission also recognizes commenters' concerns and suggestions.\47\
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\43\ See supra note 4.
\44\ See supra note 6.
\45\ See supra note 23.
\46\ See supra notes 24-28.
\47\ See PIABA Letter and Frager Letter.
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While the Commission acknowledges that FINRA's proposed amendments
to Rule 12403 might result in an increased burden in vetting additional
arbitrators, the Commission agrees with FINRA that parties would
benefit from having greater choice in selecting public arbitrators, and
that the benefits of this greater choice would outweigh the cost of
additional vetting.\48\ The Commission additionally agrees with FINRA's
assessment that the proposed alternative arbitrator selection process
suggested by one commenter \49\ would not provide the benefit of
greater choice and would unnecessarily complicate the arbitrator
selection process.\50\
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\48\ See FINRA Response Letter.
\49\ See Frager Letter.
\50\ See FINRA Response Letter.
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In addition, the Commission agrees with FINRA's assessment that the
``shortage of local arbitrators'' and the transparency of FINRA's
arbitrator list-selection process \51\ are outside the scope of the
proposal.\52\
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\51\ See PIABA Letter.
\52\ See FINRA Response Letter.
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For the reasons stated above, the Commission finds that the
proposed rule change is consistent with the Act
[[Page 64566]]
and the rules and regulations thereunder.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\53\ that the proposed rule change (SR-FINRA-2016-022) be, and
hereby is, approved.
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\53\ 15 U.S.C. 78s(b)(2).
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For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\54\
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\54\ 17 CFR 200.30-3(a)(12).
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016-22535 Filed 9-19-16; 8:45 am]
BILLING CODE 8011-01-P