Consumer advocates voicing support for both SB189 and SB 227.

Chair Hope and Members of the Courts of Justice Committee: The Financial Industry Regulatory Authority (FINRA) appreciates this opportunity to submit written testimony on Senate Bill 227 (SB 227), the Arbitration Fairness Act. FINRA is a 501(c)(6) not-for-profit regulator of the securities industry that operates under authority granted under the Securities Exchange Act of 1934 (the 1934 Act). FINRA is registered with the U.S. Securities and Exchange Commission (SEC) as a national securities association and is a self-regulatory organization of member broker-dealer firms under the 1934 Act. FINRA writes rules, examines for and enforces compliance with both FINRA rules and federal securities laws and regulations. Additionally, FINRA regularly communicates with the Virginia Division of Securities and Retail Franchising (Division) about the broker-dealer firms and their associated persons, including agents, who fall under the jurisdiction of both FINRA and the Division. FINRA rules, including the FINRA Arbitration Codes, are filed with and approved by the SEC, after a comment process and a finding by the SEC that such rules are in the public interest. The SEC regularly examines FINRA’s arbitration forum (Forum). As part of our mission to protect investors and ensure market integrity, FINRA administers the largest securities arbitration forum in the United States to assist in the resolution of disputes involving investors and broker-dealer firms and their registered employees. In its capacity as a neutral administrator of the Forum, FINRA does not have any input into the outcome of arbitrations. The Forum has 69 hearing locations across the country, including Norfolk and Richmond. We are concerned that the requirements set forth in SB 227 could potentially create a conflict between state and federal law concerning the Forum’s uniform investor protection practices. This conflict has been recognized by other states, which have exempted FINRA from arbitration-related proposals. The Forum does not qualify as a “high-volume arbitration service provider” currently. However, should that change, we are concerned about the conflict created by SB 227. For this reason, FINRA respectfully urges you to consider adding the following language to § 8.01-581.017 after line 56: “High-volume arbitration service provider” does not include an arbitration forum administered by a self-regulatory organization as defined in Section 3(a)(26) of the Securities Exchange Act of 1934 (15 U.S.C. Section 78a, et seq., as amended) and the rules and implementing regulations promulgated thereunder. If you have any questions, or if there is further information we can provide, please reach out to me at kristen.standifer@finra.org or (415) 217-1126. Thank you for your consideration. Sincerely, Kristen Standifer Senior Director, State Government Affairs

Consumer advocates voicing support for both SB189 and SB 227.

On behalf of the property owners that I and my firm represent in eminent domain cases, we appreciate Senator Perry's willingness to work with us on SB 342 and include amended language clarifying the procedure should an eminent domain case involving property subject to an open space or conservation easement. With the amendment ensuring that a locality or the Commonwealth would not be offering evidence of tax abatement in the same trial at which a property owner offers evidence of property value, we support SB 342 and believe it helps protect and preserve private property rights, especially for those owners who have chosen to devote their properties to uses which promote environmental conservation and the preservation of open spaces.