Subject: SR-FINRA-2022-024: WebForm Comments from Justine Tobin
From: Justine Tobin
Affiliation: ER of Tobin Company Securities LLC

Aug. 16, 2022



August 16, 2022

 Please don't limit what few rights we have for expungement.  I have never had to expunge but will need to with an abusive, meritless lawsuit that me and my firm are the subject of.  The securities industry is full of meritless cases led by ambulance-chasing attorneys just trying to shake firms down.  FINRA makes no effort to require EO insurance which would make EO insurance affordable, like in the architecture or accounting industries.  Right now, insurance is unaffordable for small firms.  Expungement should not be restricted - it should be expanded to protect small firms and their owners.  This proposed rule change does nothing for investors.  It just let's FINRA have a more deadly grip on its quickly disappearing base of constituents.