Subject: Regulation FD, Fair Disclosure

Date:    11/16/2000 4:20 PM
     
     
Carolyn Kurr:
     
Regulation FD, as it is now, has worked to the detriment of the 
investing public.
     
Regulation FD resultant efect has been that company officers are now 
reluctant to disclose information which would materially affect an 
investor's decision. The investing public is now getting less 
information than ever before.
     
The intent of regulation FD, was to make the playing field more level, 
such that analysts and the public would know the same information at the 
same time.
     
But that has not been the case.
     
A few recent specific examples of this are:
     
    CC, Circut City Stores: mangement witheld material information on
the decision to pull appliance sales from their stores and to engage in 
an extensive remodeling program, until after the program was in effect 
and irreversable. Should this contemplated direction have been disclosed 
to the investing public, appropriate investing decisions could have been 
made by the public.
     
    GLW, Corning: management recently decided to issue more shares and
incur more debt. Additionally, the underwriters were given stock options 
at an price of $71.00 ( if I recall correctly), when the stock was 
trading at $78.00. This was disclosed to the public after the fact, and 
not before. The result was, that after disclosing this to the public, 
the stock took an immediate plunge.This information should have been out 
in the public domain a long time sooner.
     
    The Securities and Exchange Commission should have a goal of getting
more timely information to the investing public, not less, as regulation 
FD has done. Companies should be required to disclose contemplated 
managment direction long before, than has been the present practice.
     
Sincerely, J. Michael Scott