The purpose of this letter is to provide the Securities and Exchange Commission (“SEC”) with comments on the above referenced proposed rule change which was filed by the Financial Industry Regulatory Authority, Inc. (“FINRA”) on May 13, 2024. I am a retired attorney whose prior practice was exclusively devoted to the representation of individual and institutional investors in their disputes with the securities industry. Moreover, I am the immediate past Chairman of FINRA’s National Arbitration and Mediation Committee (“NAMC”) and a former public member of the NAMC – in fact, I served in both positions during two separate and distinct terms, a former Chairman of FINRA’s Discovery Task Force Committee (“DTFC”), a former member of the Securities Investor Protection Corporation (“SIPC”) Modernization Task Force and a former President, former member and current Director Emeritus of the Public Investors Advocate Bar Association (“PIABA”). It is my understanding that the proposed amendments would amend the Code of Arbitration Procedure for Customer Disputes so as to clarify and, in some instances, amend the applicability of FINRA’s Document Production Lists to certain simplified customer arbitrations administered under FINRA Rule 12800. It is my further understanding that the proposed amendments would specifically be applicable to those documents which should be presumptively discoverable that the parties should exchange, without arbitrator or DRS staff intervention, in customer initiated “paper” and “special” simplified arbitration proceedings. It is my opinion that providing customers in these simplified arbitration proceedings with the option to use FINRA’s Document Production Lists, many of which are initiated on a pro-se basis, would increase customer awareness and understanding of the discovery process and the likelihood that customers would be able to discover the documents and information that are relevant to their arbitrations. Based on the preceding, it is my further opinion that the proposed amendments should be approved by the SEC on an expedited basis. Thank you for providing me with the opportunity to submit my comments on this matter.