Subject: SR-FINRA-2023-013
From: Lynne Brundage
Affiliation:

Jan. 5, 2024

Good morning,
I would like to comment on the above referenced rule that discusses NAR during mediation and arbitration. Although I believe this contact may exceed the cutoff date for comments, I do believe that mine has merit none the less and I respectfully request that you read it, if for nothing else, food for thought. I thank you in advance.

I was a victim of the FINRA process. It is fraught with discreet corruption. I was not an NAR, in fact quite the opposite. I came armed with an attorney and a highly respected expert witness. I had expended 6 figures to end up in front of a mediator, because the prospect of making it to the arbitration held an even bleaker financial outlay.

This process is controlled by the “repeat players” in my case Morgan Stanley. No disrespect intended but it seems the discussion regarding the competency of NAR/ alternative representation has already been decided by the higher courts. If Ted Bundy can represent himself then I would welcome Mickey Mouse.

The records speak for themselves. The legitimacy of any FINRA alternative dispute resolution rivals the Constitution. This is not due process, it isn’t less expensive nor is it expedited. In fact it’s a very simple and well established procedure.

It should concern FINRA that the  overwhelming majority of cases are settled in mediation for pennies  on the dollar. That is the real shark tank. The level of vested interest that they have in keeping the big banks happy is in and of itself a miscarriage of justice.  Yet they are praised - and their biggest selling feature - painting the gloom and doom prospect of actually making it in front of the arbitrators.

They are all opportunists who prey on those, that by virtue of how white collar crimes are perceived, have allowed an alternate to a constitutionally promised judicial process, punish the victims.

Financial damage at the hands of someone else can have devastating effects. Compound that with the legal fees associated -  murderers are afforded so much more legal concession. I would not be too concerned with non attorneys misquoting laws - the bank attorneys do it in every single dispute.

Thank you for your time.
Lynne Brundage



Lynne Brundage
Elliott Group Service, LLC.