Public Investors Arbitration Bar Association 2010 Officers Scott R. Shewan President May 11, 2010 Peter J. Mougey Vice-President/ President-Elect VIA E-MAIL To: rule-comments@sec.gov Jenice L. Malecki Secretary Ms. Elizabeth M. Murphy, Secretary Ryan K. Bakhtiari Treasurer Securities and Exchange Commission 100 F Street, N.E. 2010 Directors Washington, D.C. 20549 Ryan K. Bakhtiari California Gail E. Boliver RE: File No. SR-FINRA-2010-012 Iowa Proposed Rule Change to Amend FINRA Rule 8312 (FINRA Steven B. Caruso BrokerCheck Disclosure) New York Jason Doss Georgia Dear Ms. Murphy: Scott Ilgenfritz Florida On behalf of the Public Investors Arbitration Bar Association (“PIABA”), William A. Jacobson I thank the Commission for this opportunity to comment on the above-referenced New York rule change proposal that would amend FINRA Rule 8312 to expand the Richard A. Lewins information released through BrokerCheck, and to provide for BrokerCheck Texas dispute process. PIABA is a national, not-for-profit bar association comprised of Jenice L. Malecki more than 460 attorneys, including law school professors and former regulators, New York who devote a significant portion of their practice to the representation of public C. Thomas Mason Arizona investors in securities arbitrations. Accordingly, our members and their clients Peter J. Mougey have a strong interest in FINRA rules that protect public investors, ...