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U.S. Securities and Exchange Commission

Author:  Eddie Arrington  at Internet
Date:    04/20/2000  6:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
    The Legal and Compliance Division of the Securities Industry
Association believes "...that communications between [a company] and 
individual analysts or small groups of analysts contribute to the 
overall mix of information in the marketplace, greater accuracy of 
market prices, less volatility and, in general, greater efficiency....."
     
    I believe the SIA wants to control information for their own
benefit.  After all, if individual investors get the same information 
that the analysts get, and at the same time, they might be able to use 
the information and bypass the "professionals" altogether.
    And volatility?  Did these idiots sleep through the last two weeks?
I think it's about time we leveled the playing field.
     
Eddie Arrington
Denver, CO
     

     Author:  "THOMAS BALLARD "  at Internet
Date:    04/20/2000  7:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
In reference to the above-captioned subject, I suggest that individual investors
as well as the general public should have equal access to all pertienent 
company, as well as corporate information. 
     

     Author:  Ted  at Internet
Date:    04/20/2000  8:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 

To The SEC:

APPROVE subject regulation on fair disclosure of information by publicly 
traded companies to the public.

I have been an online individual investor for
the past four years. My investment style is short-term to long-term in 
seeking growth and value. To date I have been very successful and one of 
the main things I have learned is to go 180 degrees from the
recommendations of analysts. When they say Buy, they have just finished 
Selling, so it is the time to Sell. When they say Hold, it is usually the 
time to Buy. Point being, information from and by publicly traded companies 
should have fair disclosure to the public, not just select analysts. 
If analysts were so sharp, then why does 80% of the mutual funds not beat 
the S&P 500? Analysts have an unfair advantage to the information
and often provide or release ratings and advice in their own best interest, 
not the best interest of the individual investor!!!!!

Respectfully,
Theodore R. Barrett
Albany, GA
(912) 435-2580

     Author:  "Joan Behnke"  at Internet
Date:    04/20/2000  8:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am in favor.
     
Joan Behnke
Investor

     Author:   at Internet
Date:    04/20/2000  4:55 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
     
     
Please, please, please pass this legislation.  Financial analysts do not deserve
any more special access to financial information than does the average investor.
As seen in the wild market swings of late, restricting information in the 
current way is no guarantee of reducing market volatility.  Who knows - it may 
even lessen the volatility.  It is pure conjecture to conclude otherwise.
     
Regards,
  Dean Bethke

     Author:  "Tim Beyers"  at Internet
Date:    04/20/2000  7:01 PM
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TO: RULE-COMMENTS at 03SEC
CC:  at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
     
Dear sirs,
     
The SIA's filing with you suggests that individual investors don't purchase 
stock without first consulting the so-called wisdom of analyst reports.  In 
a word: hogwash.
     
In the short time I've been an investor, I've used several resources to pick 
stocks. But I've never picked a stock on the basis of an analyst 
recommendation or report.  How insulting is it to tell investors that we're 
incapable of coming to our own conclusions without Wall Street expertise?  I 
can think for myself, and apparently pretty well too: since December, when I 
opened a discount brokerage account and the markets first started their 
current descent, my portfolio is up 38 percent.  Not too bad for someone who 
doesn't employ a full-service broker and a team of analysts.
     
I'll admit that I'm being sarcastic and perhaps a bit rude.  But I take 
serious offense with the notion that I can't make an intelligent investment 
choice without first consulting a professional.  But there's a separate and 
equally dangerous notion in the SIA's filing that bears discussion here
too -- that is, that analysts are paid to ferret out negative information, 
and do so to protect investors.  Forgive me for repeating myself but, again: 
hogwash.
     
To begin with, consider for a moment how often analysts will issue a 'sell' 
rating on a stock of a company they cover.  Such occurrences almost *never* 
happen.  Why?  I can only speculate but reports in the Wall Street Journal 
and other credible publications say that analysts won't tell clients to out 
and out 'sell' for fear that companies will retaliate by withholding 
critical information such as earnings estimates, sales figures, time with 
the CEO and so on. If anything, this kind of practice -- where companies 
manipulate their stock ratings through selective briefings with weak-kneed 
analysts -- should be of the utmost concern to the SEC, because it directly 
impacts analysts' credibility with investors.
     
That's an important point, and in my opinion it bears more discussion than 
the SIA's filing. Now here's the bigger picture: it's a new world. 
Investors are smarter and more empowered than ever.  The work securities
analysts do -- and some of it is very valuable -- is playing an increasingly 
smaller role in helping investors formulate opinions and decisions. 
Investors can and should have access to all the data they can in conducting 
intelligent investing, and that includes getting the same data securities 
analysts do, at the same time.
     
Let analysts make their money as *analysts* -- interpreters of data -- 
rather than as gatekeepers of it, as they mostly do today.
     
Thank you for your time and attention,
     
Tim Beyers
Vice President
UpStart Communications
tbeyers@upstart.com
     

     Author:  lynn Marie blackman  at Internet
Date:    04/20/2000  8:00 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD
------------------------------- Message Contents 
Please add my vote to those in favor of proposed 
Regulation FD.   Full disclosure of information on 
publicly traded companies can only improve things for 
indavidual investors.
I understand that the SIA is against Reg FD.  In thruth 
most investors will not take advantage of the 
additional to information.   But, that is what full 
service brokers are for.  To provide investment 
services  to those that don't want to be bothered with 
the details.   But for those of us that want equal 
access to information, we should have it.   What will 
it hurt?
     
Dave Blackman
     

     Author:  "jlblue"  at Internet
Date:    04/20/2000  9:05 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I object to companies giving information to securities analysts that is not 
available to individual investors. This is not fair. Period.
     
James Blue
15241 Springfield Road
Darnestown, MD 20874
     

     Author:  "Joe & Brenda Boehnlein"  at Internet
Date:    04/20/2000  9:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am sounding in regard to the proposed regulation listed in the subject.
     
      I firmly believe that anything that will give greater information
concerning investments to individuals cannot be anything except benificial to 
the public at large. Any investor that wishes to take the time to study the 
information that would be provided can rest assured that his decisions are based
on his own observations, and not the advise of those who may not have that 
individual's best interest at heart.
The free flow of information adds to the well-being of the economy as a whole, 
the limitaion of knowledge enrichs some at the cost of society.
     
Joe Boehnlein
     

     Author:  "Joe & Brenda Boehnlein"  at Internet
Date:    04/20/2000  9:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am sounding in regard to the proposed regulation listed in the subject.
     
      I firmly believe that anything that will give greater information
concerning investments to individuals cannot be anything except benificial to 
the public at large. Any investor that wishes to take the time to study the 
information that would be provided can rest assured that his decisions are based
on his own observations, and not the advise of those who may not have that 
individual's best interest at heart.
The free flow of information adds to the well-being of the economy as a whole, 
the limitaion of knowledge enrichs some at the cost of society.
     
Joe Boehnlein
     

     Author:  "Glen Bollinger"  at Internet
Date:    04/20/2000  4:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD
------------------------------- Message Contents 
In fairness to the public at large, there is no question as to what the decision
MUST be regarding proposed Regulation FD.  Each of us is entitled to equal 
accessability of information from a company in which we have an interest.  
     

     Author:  "Burton L. Bostwick"  at Internet
Date:    04/20/2000  9:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Gentlemen:
     
With the advent of the Internet, we have seen a vast migration from 'indirect' 
investment to direct on-line investment.  This has resulted, among other things 
in: 1) much lower commissions; 2) real-time online level 2 quotes free to the 
public; 3) a proliferation of industry and research information readily 
available to the public; 4) online 10Ks and other SEC reporting.  By and large, 
the public seems to have managed this transformation rather well.
     
It is now time to remove other barriers to a level playing field and a 
transparent investment process.  Only the most tortuous of reasoning could 
justify the continued practice of favored analysts receiving access to insider 
information that benefits an incredibly small proportion of the investing 
public.  Moreover, the practice encourages favoritism and deception.  With all 
the means of communication available to public companies today, there is every 
reason to keep the investing public informed of both favorable and unfavorable 
information.  And, if it is made public, the companies can be held accountable 
for it.
     
I strongly urge the Commission to take further steps in its long history of 
protecting the investing public by terminating the practice of limited 
information disclosure to privileged sources.
     
Very truly yours,
     
Burton L. Bostwick
     

     Author:  "Richard Bowers"  at Internet
Date:    04/20/2000  9:07 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I believe it to be a necessity to have fair and open communications, rather than
closed discussion. The American exchange system is based on the idea that 
sharing insider information is a bad thing. Selectively calling certain 
expressions of this sharing "good" does not make any sense, when they are still 
based on certain powerful individuals being the recipients. I am in favor of any
regulation that requires external communications to be completely above board 
and public.
     
Richard Bowers
     

     Author:  mike B  at Internet
Date:    04/20/2000  9:37 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Good day.
     
I believe the proposed rule is good for the individual investor. Under the 
current system the analysts' function is not so much to advise as to 
manipulate. By keeping certain information private they do not allow for 
true analysis of the comapny by the investor, but only offer their own 
opinion, which we are supposed to believe because they have self-delcared as 
analysts.
     
The analysts can cause the very effects they purport to be deriving from the 
proprietary information simply because, for whatever reason, the general 
public has come to believe in them almost as if they were the Oracles of 
old. If many analysts say buy the stock goes up because many buy based only 
on the anlaysts' reports. Which is cause and which effect here? Does the 
stock go up because the prediction is correct, or is the prediction 
self-fulfilling because by advising a buy they know this will, at least 
temporarily, increase the price.
     
It is more important that the individual investor have access to all of the 
information given to the analysts so that an independent informed opinion 
can be reached. Without this information we are at the mercy of where the 
analysts may -want- a stock to go rather than where it -should- go.
     
An informed public is of the most benefit to the market as a whole. Perhaps 
with a properly informed society of investors we wouldn't even need 
analysts. Could this be a possible reason for the industry rejection of the 
proposed reg?
     
Michael M. Boy

     Author:  "Thomas A. Brandon"  at Internet
Date:    04/20/2000  9:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I feel that I should be privy to the same information that analysts 
receive regarding communications from any given company.  Why is it we 
can retrieve information from the government through the Freedom of 
Information Act, but cannot for our personal investments. If anything, I 
would think this would encourage analysts to do their homework, as 
credibility becomes the issue here.  And it should be my choice, as an 
investor, given the same information, whether I go with their opinion, 
or my own.
     
Regards,
     
Thomas A. Brandon
     

     Author:  "Andy Brown"  at Internet
Date:    04/20/2000  6:40 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Re: Proposed Regulation FD: File No. S7-31-99
     
Sirs,
     
I am all for allowing individual investors equal access to the same 
information as institutional investors. As a owner of a small business and 
as the first employee of an extremely successful semi-conductor company, I 
believe that, despite the Securities Industries Association's opinion, I am 
well qualified to make my own judgements as the relative merits of companies 
that I may invest in. In fact, I believe, that for many industries that I am 
probably more qualified than most professional "analysts".
The United States was founded on the promises of free speech, and by 
extension the free flow of information. Today, the greatest harm that one 
can do to the economy is restrict this free flow and exchange of ideas. 
So please, help eliminate the monopolistic position that "analysts" have
over the individual consumer. I'd be interested in what My companies have to 
say.
     
Regards,
     
Andy Brown
andy.brown@cportcorp.com
     

     Author:   at Internet
Date:    04/20/2000  9:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To the SEC:
     
I want to strongly urge you to ratify this proposal that will promote the 
fair disclosure of relevant company information to the investing public on 
the same timing as financial analysts.  I find the position against this 
proposal by the Securities Industry Association as predictable as it is 
absurd.  If, as they assert, that financial analysts provide a necessary and 
stabilizing influence on the markets, why do they do no better than anyone 
else in beating the market averages?  How do they keep the market from being 
more volatile by getting information first?  Personally, I've made a lot more 
money by using these analysts as contrary indicators of where a company is 
really headed.
     
The main reason that this measure should be passed is an issue of fairness. As 
individual investors now have the tools to make their own decisions, it is 
only fair to level the playing field with the professionals.  There is 
absolutely no justification in the current system that allows institutions to 
make substantial additions or subtractions to their holdings based on 
information before the general public gets it.  In my opinion, this advantage 
is no different from insider information which is already illegal.  Please 
ratify this rule for the benefit of all investors.
     
Sincerely,
     
Barry Bryant
43 Falling Brook Rd.
Fairport, NY  14450 

     Author:  Britt  at Internet
Date:    04/20/2000  8:10 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Hi,
     
The proposed rule makes sense.
     
By not passing it all you do is ensure that the individual investor is 
at a loss information-wise and must perforce make use of paid analysts 
in order to make wise decisions. While good for the analysts, this is 
bad for the individual.
     
I sincerely hope you pass this rule.
     
Britt D. Burton...
     

     Author:  "Kathleen Carter"  at Internet
Date:    04/20/2000  6:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I wish to express my support of the proposed regulation for 
opening public company
communications to the public. I do not believe that analysts 
necessarily represent
MY interests when they are interpreting company comments for 
me. I would much
prefer to hear and interpret my own results.
     
I think it is beneficial to keep the questions limited to 
analysts. However, the answers
should be available to the public. After all, these are 
"public" companies we are
talking about. The "public" owns the stock in these 
companies, either directly or
through funds.
     
The analysts are, of course, against this regulation. 
However, that pretty much
proves to me that it is a good one. I believe Wall Street 
still operates a very closed
society. While that is very lucrative to those insiders, it 
is not beneficial to me or to
the companies I own.
     
Thank you for your consideration of this comment. I'm just a 
little investor, but I
hope that you'll hear from lots of little investors who feel 
like I do.
     
Kathleen S. Carter
8439 Peachtree Ave.
Newark, CA  94560
kscarter@usa.net

     Author:  Walter  at Internet
Date:    04/20/2000  7:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File# S7-31-99
------------------------------- Message Contents 
I cannot imagine any greater benefit to all interested parties in the 
availability of business news. Simultaneous full disclosure of all 
information of any nature to the full public at one time should be the 
norm.
     
Walter Chenausky
9 Nanigian Rd
Paxton, Ma 01612
     

     Author:  "Alan C. Christensen; Ph.D."  at Internet
Date:    04/20/2000  8:00 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I would like to respond to the comments of the Ad Hoc Working Group on 
Proposed Regulation FD and the Legal and Compliance Division of the 
Securities Industry Association ("SIA") reported at 
http://www.sec.gov/rules/proposed/s73199/spencer1.htm
     
In section II part C (General Comments; Analyst's Perspective) is a very 
revealing sentence:
     
"Leveling the playing field for analysts, as among themselves and vis-a-vis 
the general public, will undermine the great advantages of the current 
system. "
     
This gets at the crux of the matter.  The SIA is opposed to a level playing 
field for analysts vis-a-vis the general public, and they admit it.  their 
justifications are very weak compared to the goal of an open system and a 
level playing field.  Some companies already level the playing field to a 
large extent and this has not destroyed the markets.  Pfizer, for example, 
publicly issues a question and answer sheet along with their financial 
statements.  Cisco, Microsoft and Intel make sessions with analysts 
publicly available on the web in real time.
     
Any objections by the SIA are just a smokescreen for their real issue: 
power.  I strongly support the philosophies and ideals of Chairman Levitt 
(http://www.sec.gov/news/speeches/spch304.htm), and strongly support the 
proposed regulation.
     
Alan C. Christensen
Associate Professor
University of Nebraska, Lincoln

Author:  Hal Clark  at Internet
Date:    04/20/2000  5:54 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I fully support new regulation that would require public disclosure of company 
information.   I am insulted by the lobbying arguments put forth by the SIA that
they need to run interference on the information for my own good.  Someone needs
to send them a wake up call that the world is not the same place it was 10 years
ago and as much as they would like to turn the clock back it's not going to 
happen.
     
Hal Clark, EISG Program Administrator 
San Diego State University Foundation 
5250 Campanile Dr., MC 1934 (3rd Floor) 
San Diego, CA 92182-1934
Phone: (619) 594-1158
Fax: (619) 594-0996
Email: hclark@projects.sdsu.edu

     
Author:  "Dennis Cleary"  at Internet
Date:    04/20/2000  5:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: hogwash from the Securities and Exchange Commission
------------------------------- Message Contents 
Dear SEC,
     
Thanks for protecting insiders and allowing a privileged few such as 
Greenspan and his ilk to keep pulling the wool over American investors and 
their supposedly stupid eyes.  And while you are at it, get decimals into 
the trading place so consumers are not underdogs to crooked brokers. 
Mr.Leavitt has to either resign or redo the rules that govern Wall Street. 
Stop adotping rules that insult individual investors. Pass rules that 
protect investors from stupid analysts who always lose money for investors 
with their hype and "make market" psychology.  Perhaps you should pass a law 
that no analyst can operate on the Web or the media unless his or her 
portfolio is available to the public.  Then we will see who is unethical and 
benefitting consumers and investors.
     
Dennis James Cleary
215 Greenbush Avenue
Folsom, CA 95630
April 17, 2000
     
	 

     
Author:   at Internet
Date:    04/20/2000  9:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I wish to go on record opposing the proposed rule to allow companies to 
provide information to selected financial people. 
     
In this age of the internet and the abundance of financial information 
available to everyone, it would be a giant step back to allow limited 
distribution of information. This select release will put power in the hands 
of the few and provide unlimited opportunity for abuse of that power. One 
could see numerous cases where information was provided to select clients 
before being released to the masses.
     
It would be a mistake to allow limited release of financial information to 
select individuals.
     
R. Cleary
	 

     
Author:   at Internet
Date:    04/20/2000  9:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Leveling the playing field
------------------------------- Message Contents 
In this day and age of computers and lightning speed information, the 
playiing field needs to be even for everyone. Otherwise, it just remains so 
much "insider information" to the analyst first.
     
Ms. Cline
	 

Author:  "Dave Coleman"  at Internet
Date:    04/20/2000  8:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To Whom It May Concern:
     
I am writing to register my strong support for Proposed Regulation FD. It is 
my considered opinion that financial information relevant to me as an 
individual stock owner should be made available to me on the same basis as 
provided to professional stock analysts. If professional analysts truly 
bring additional "value added" to this financial information, then the free 
market will find consumers listening to what they have to say. But if, as I 
suspect, these analysts are largely offering guesswork and divination 
painted with the thin coat of authority granted to them by inside 
information, then they deserve to have their own stock devalued in the 
marketplace.
     
Thank you for your time.
     
     
Dave Coleman
Germantown, MD
	 

     
Author:  "donnamary"  at Internet
Date:    04/20/2000  8:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation
------------------------------- Message Contents 
I would like to say that in regard to Proposed Regulation FD, File Number 
S7-31-99 that the public should have access to the same information that Wall 
Street analysts have. There are many instances in my investment history where 
the information told to me by a full service broker was not only incorrect, but 
by my acting upon it in good faith, led to the gain of the brokerage house at my
financial expense. Please seriously consider the millions of Americans who are 
striving to do Due Diligence on the companies in this country we invest in. It 
is not a level playing field. Please contemplate this proposed regulation 
seriously from the perspective of the individual struggling to augment social 
security and retirement plans via good investments make in the capital markets, 
based upon information available. Thank you. Regards,
     
Donna Conley
     
donnamary@msn.com 
	 

     
Author:  Larry Connolly  at Internet
Date:    04/20/2000  5:32 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S.7-31-99
------------------------------- Message Contents 
I write in favor of your proposed regulation to ensure that public companies 
broadcast all messages about significant events and forecasts to the general 
public BEFORE any private discussions with securities analysts.  It has been 
shown time and again that securities analysts tip off their own houses first 
(which is understandable, since that is the way they get the message out to 
the general public.
     
I agree with the SIA that many people are ill-equipped to analyze and 
interpret some companies' press releases, but the same people are often hurt 
by a misreading of analysts comments.  Analysts usually issue upgrades 
(downgrades) after the good news (bad news) has been announced and is 
reflected in the companies' stock prices.  I have been the chief accountant at 
a mid-sized publicly held company where I have seen certain analysts being 
"schmoozed" by top management.  While I believe those analysts' opinions were 
not compromised in a major way, I do think they were influenced at the 
margins.  The company would not be able to exert such influence over the 
public at large and/or all securities analysts at large.
     
Sincerely,
Lawrence P Connolly
     

     
Author:  CJ Connoy  at Internet
Date:    04/20/2000  5:03 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Proposed Regulation FD: File No. S7-31-99
     
I support this rule.
     
Charles J. Connoy Jr.
Oceanside, CA
     
	 

Author:  "K Corbin"  at Internet
Date:    04/20/2000  9:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I'm an individual investor who has read about the above proposed rule on the 
Motley Fool website.  I would like to comment on the proposed rule, and show my 
support for its adoption.
     
Todays investing marketplace is quite different from what we previously had. 
Most individual investors have access to a broad array of information. We study 
our investments carefully, and try to make the best decisions we can about the 
companies in which we choose to invest.
     
The practice of companies disclosing information to select analysts in closed 
meetings is anathema to the open flow of information.  Let us be truthful for a 
minute...companies and analysts often have a "symbiotic" relationship.  Analysts
will get inside information from a company because the company is being promoted
by the brokerage that the analyst works for.  This benefits only the customers 
that use that broker, because the "upgrade" (or worse, the downgrade) which 
inevitably follows is shared in-house first before the rest of us see it.  I 
can't tell you the times I've been frustrated by analysts that seemingly get 
information before the rest of us, and who influence the price of a company's 
stock. There is nothing better than to see an analyst downgrade a stock, then 
after the price has eroded sufficiently, that same analyst will then upgrade the
stock a few days later.  Wonderful.  
     
Please prevent this type of conduct and adopt the above rule.  The only people 
against this rule are those with a vested interest in maintaining the status 
quo, and preserving a truly valuable commodity, inside information, for their 
own use. 
     
Thank you. 
     
     
Kevin Corbin
Ann Arbor, Michigan
     

Author:   at Internet
Date:    04/20/2000  9:16 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
These are public companies. We The People should have unlimited access, 
nothing less is fair.      William Davis
     
	 

     
Author:  Ron DeLong  at Internet
Date:    04/20/2000  4:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am an individual investor with several hundred thousand in a trading 
account. I feel that I am at a large disadvantage because of special 
interests and private communications. I would like to remove some of those 
disadvantages by having public disclosure of information at the same time 
for all parties. The Internet is a perfect tool for this. I realize 
everyone does not have access so other media should be used as well. I 
would like to have access without pay some third party a large amount.
	 

     
Author:  Steven Dern  at Internet
Date:    04/20/2000  6:13 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am in support of the rule requiring fair public disclosure. 
Steven Dern
	 

     
Author:   at Internet
Date:    04/20/2000  8:52 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
     The SIA filling makes the case that if private Q&A sessions between
companies and analyst were not available that... Company announcements "are 
likely to take on the orchestrated character of a Presidential news 
conference". I think this is a good analogy. However the strength of the 
argument runs contrary to the SEC's filing. In making that argument the SIA 
working group is arguing for closed door Presidential interviewing process 
and that runs contrary to common sense, public opinion and the average mans 
experience. Yes our current system of hashing out the facts of the 
Presidency has flaws but you won't find anyone asking for less access. Its 
a lot like our legal system... it looks pretty bad until you look at other 
option. Politicians may try to control the release of information but in 
the end the public usually finds out. That wasn't true back when the news 
organizations behaved more like and good old boys that investigative 
journalists.
     Outlawing private Q&A sessions will probably change the way the public
reacts to company disclosures. And there is arguably a case to be made for 
the SIA contention that private meetings reduce volatility. But what is 
entirely clear is that Wall Street insiders primarily use the information 
gained from private sessions to line their own pockets as well as their 
best clients. The theoretically reduce volatility brought about by this 
profit taking and reselling of this insider info the public is only an 
unintended side affect of their primary motive.
     
End the private sessions! Level the playing field!
     
Stephen De Shazo
Individual investor
     
	 

     
Author:  Prem Devanbu  at Internet
Date:    04/20/2000  5:43 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sirs,
     
I think it is  anti-democratic, anti-free market and elitist for companies 
to release information selectively to certain groups of analysts.
     
Rapidity and breadth of information distribution is key to greater 
market efficiency.
     
thank you.
--
Premkumar Devanbu                       530 752 7324 (voice) 
CS Dept., University of California,     530 752 4767 (Fax)
Engineering II, Room 2063               http://www.cs.ucdavis.edu/~devanbu 
Davis, California 95616, USA            devanbu@cs.ucdavis.edu
     
(Affiliation shown for information only. The University of California, 
or the department of Computer Science,
do not necessarily hold any of the views expressed in this message)
	 

     
	 
Author:   at Internet
Date:    04/20/2000  9:35 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
I believe that full disclosure of company financial data to ALL rather than a 
select few, i.e., certain employees of brokerage firms, better serves the 
general public.  My reasons are as follows:
     
1) By giving information out selectively to analysts, it creates, in effect, 
an information monopoly with those with access to the information obtaining a 
competitive advantage.  This "monopoly of information"  allows that group to 
make more money because of their access.  We can only get that information by 
paying for it.  Hence it is. in effect, "restraint of trade".  
     
2) The concept that the "analyst" given the information can use it best(for 
the rest of us?) is elitist.  The vast majority of these analysts probably 
have no more or less business education that many of the general public who 
would use this information.  If "they"(the analysts) are smarter than "us" 
(general public) than why isn't everyone making gobs of money?
     
3) The belief that these analysts serve a quasi "media" function by ferreting 
out information would not change if the information were available to the 
general public.  Inactive investors who rely solely on the advice of these 
analysts would continue to do so.  Typically, they are the ones who don't have 
the time, inclination or ability to decipher the data.  Active investors might 
chose to do so.  Therefore, the analyst could continue to perform their 
"media" role, adding value to their customers.  Others could chose to make 
their own investment decisions.  In the long run, if the analysts are more 
efficient, we will all come back!
     
4) Given the current volatility of the markets, is there any point in 
continuing the premise that analysts help manage volatility?
     
     
Finally, keep in mind that you must look at input you get from the groups 
impacted, i.e., the brokerage forms, will say any kind of baloney to protect, 
in effect their jobs.  I believe you should pay more attention to those who do 
not have as big vested interest in the outcome.
     
I could go on, but my major point is let the open market decide who is most 
efficient are managing this economic data.  Why should a govermental rule 
protect from competition a specific job function like these analyst.  Again a 
free market demonstrate the most effective means and results.
     
Thank you!
     
David Dieckelman
Buffalo Grove, Il   60089

     
	Author:  Roger Dooley  at Internet
Date:    04/20/2000  5:51 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
SEC,
At my grade school, many years ago, there was an arched inscription over 
the main door. It said "The Truth Will Set Us Free."
     
Anything less than the truth and full disclosure in public matters is an 
abomination to democracy. An informed citizenry, whether voting or 
investing, is the only path envisioned by our founding fathers. Now do 
the right thing and level the playing field for individual investors.
     
Roger Dooley
An American investor who wants the facts
     

Author:  Juan Duarte  at Internet
Date:    04/20/2000  6:36 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To the regulators:
     
All investors and potential investors should be allowed to receive any 
information that a public company offers to the public. A few selected 
to learn about disclosures does not make a company public it makes it a 
private company.
     
Juan Duarte
	 

     
Author:   at Internet
Date:    04/20/2000  9:34 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As an individual investor, I would like to support the proposed regulation. 
Since I am the one putting my money at risk, I should have the same access at 
the same time as anyone else to a company's disclosure information.  There is 
no reasonable justification for a Wall Street analyst to receive any of this 
information before I do.  It is common knowledge that some analysts have 
fairly cozy relationships with some companies or industry associations--maybe 
not to the extent of receiving legally actionable inside information, but 
closer than the typical individual investor nonetheless--which could enable 
these analysts to put a "spin" on this information that would tend to bolster 
their own positions.  Should companies be prohibited from making these 
selective "leaks", individual investors like me would be able to come to their 
own conclusions without having to cut through excessive amounts of 
self-serving analyst hype.  Please adopt this common-sense regulation.
     
J. Dubiel
Stafford, VA
tiefi@aol.com 
	 

Author:  "JOHN V DU BRIAN"  at Internet
Date:    04/20/2000  8:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC:  at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sirs: 
     
    Your position on maintaining the cloak of secrecy surrounding the
communications between analysts and company executives smacks of elitist disdain
for the intelligence of the independent investor. It sounds to me like the "good
ol' boy network" hard at work protecting your collective "rice bowls."
     
    Until the back-office relationships between analysts and investment bankers
and the companies in which they are vested are trumpeted as loudly as the 
info-merciless that often times pass for analysis, I, for one, regard much, if 
not most, of the harangue as Manhattan's version of the Home Shopping Network. 
     
    This not to say that I don't pay attention to the analysts' opinions.... for
I know very well lots of people do. I know they will be swayed, and there will 
probably be some movement one way or another in stock prices. But, as a long 
term investor, I really don't care if the stock jumps or dips from one day to 
the next. I know what I know about the company and its long term prospects, and 
that is sufficient for me. Do you really think I should make an investment 
decision based on one person's interpretation of "voice inflection" or "choice 
of words?" Should I not buy, or should I sell, because two people have a 
personality conflict?
     
    When the SEC comes out in favor of a level playing field, I may re-evaluate
my position. In the meantime, I see the SEC, the analysts, the investment 
bankers, and the old-line brokerage houses circling the wagons in a futile 
defense of each other's turf and bloated life-styles. 
     
    Perhaps you might consider using this line the next time you are asked to
share what you hold so closely:
     
"Let them eat cake!"  
     
it worked wonders for the originator.
     
Good Luck,
     
     
     
Jack DuBrian
     

     
Author:   at Internet
Date:    04/20/2000  9:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
Sirs, 
It is imperative that the investing playing field be level for both the 
individual investor and professional stock analysts and investment firms. For 
a publicly owned company to selectively disseminate information to a small 
select group of people before giving that same information to the general 
investing public is no different than "inside trading" facilitated by the 
public company.  I support your proprosed new rule.
     
rwduPriest.
	 

     
Author:  "Alan Earp-Jones"  at Internet
Date:    04/20/2000  5:06 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: SEC ruling
------------------------------- Message Contents 
I am surpised that there is any debate about the need to level the playing field
. The objections from the industry prove that they are a self serving old boys 
club. The more transparent and timely company information is made to everyone 
the better.
     
	 

     
Author:   at Internet
Date:    04/20/2000  8:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: public information
------------------------------- Message Contents 
To Whom It May Concern:
All companies should make information public immediately and not give it to 
analysts beforehand.  We, the public, do not need to be protected. We have 
every right to get this information at the same time as analysts do.
Thank
Cherry Valley Editions
	 

     
Author:  Paul Elliott  at Internet
Date:    04/20/2000  8:16 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As an individual investor, I fully support the full and complete 
disclosure of corporate information to both analysts and the general 
public.
     
Where would we be if the current disclosure rules were also the rule for 
financial statements?  Hasn't disclosure here improved business analysis 
and efficiencies?
     
For those who can't or don't want to digest "full disclosure", let them 
hire or pay analysts to do it for them.  That's efficiency!
     
Give me the right to decide whether or not I can digest the full 
disclosure, so I might be able to make decisions in the same manner and 
time frame allowed to the (currently) privileged few.
     
	 

     
Author:  Bob & Rosemary Emnett  at Internet
Date:    04/20/2000  8:19 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD
------------------------------- Message Contents 
Madam or Sir:
     
I have read the proposed Regulation FD on selective disclosure of 
information and also some of the comments by the Securities Industry 
Association (SIA) opposing this regulation.
     
I strongly endorse Regulation FD. I am an individual investor who does 
his own analysis and uses a discount broker. The current, common 
practice of revealing information to investment firms and/or analysts 
puts me at a significant disadvantage. I have seen stocks that I own or 
am watching move one direction or another by 10% with no news to be 
found - only to see a news item that could explain the move appear the 
following day.
     
The SIA's opposition is at best a farce. Their real concern is clearly 
to maintain an unfair advantage for their analysts and favored large 
clients. For example, if as claimed in one of their comments that their 
analysts ferret out unfavorable information on companies, why are so
very few companies followed by these analysts ever rated Sell or Strong Sell?
     
The only way to be fair to all investors is to require disclosures to be 
made in a public manner. The companies are free to put their own spin on 
any news so released, but everyone should have equal access. Further, if 
after this public disclosure, analysts wish to add their opinions, I am 
certain they will do so. The public is then free to believe whomever 
they have confidence in.
     
I am certain that there exist individual investors who need professional 
help. Let them get it from the securities industry if they wish. 
However, the current system is prejudicial against those of us who do 
not need such help.
     
     
Robert F. Emnett, Ph.D.
     
	 

Author:  David Evans  at Internet
Date:    04/20/2000  5:19 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Hello,
     
My personal view is that it is unfair that any group should obtain 
information about a company or its performance in advance of the 
rest of the market. Ergo, why should security analysts be privy to 
special briefings. This allows them a time margin to exploit the 
news before the rest of the participants. 
     
Many people invest directly. The rise of on-line discount brokerage 
would seem to attest to its popularity. Should this group be at a 
disadvantage because they want more control over their investments? 
I would argue no. They deserve the same rights and that private 
briefings to brokerage houses is nothing more than a subtle form
on insider trading.
     
Sincerely,
     
David Evans
     
  Any statements or comments are personal and do not represent the views of 
                               Oracle Corporation.

     
Author:  Robert Fagen  at Internet
Date:    04/20/2000  5:02 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I think that in a public market it is important that all participants have 
equal access to publicly required information. Regulation FD would go along 
way towards equalizing access to information needed to make intelligent 
investment decisions. It is not surprising that the Legal and Compliance 
Division of the Securities Industry Association recently provided public 
comments on this proposed regulation. It is also not surprising that their 
commentary focused on the importance of maintaining the status quo, eg. 
analysts get more information and they get it earlier than the general public.
     
With the technology available today, it is a very small incremental effort 
to allow instant access to everyone over providing access to only the Wall 
Street Elite.
     
I strongly encourage enactment of Regulation FD.
     
Regards,
     
Robert Fagen
Private Investor
     
     
	 

     
Author:  "Paul Feng"  at Internet
Date:    04/20/2000  5:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I believe that this regulation should be approved, and that the arguments of 
the Securities Industry Association are disingenuous and designed to serve 
the interests of the insular securities industry.
     
-Paul Feng
     
	 

     
Author:  Patrick Foley  at Internet
Date:    04/20/2000  8:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents 
I think individual investors should have the same information as do Wall 
Street Analysists.  The only way they help stabalize the market is by 
selling off their interests before the bad earnings report reach the 
general public.  I want a level playing feild.
     
	 

     
Author:  "Forsythe; Richard"  at Internet
Date:    04/20/2000  5:05 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear SEC,
     
The current system of "behind the scenes" analyst briefings and conferences 
is outrageously unfair to small investors. As recipients of inside 
information regarding a company and its prospects, analysts, and their 
favored clients, reap the obvious and natural benefit of that inside 
information to the detriment of small investors.
     
I have personally seen stock movements that appear unexplained, only 
subsequently to discover that analyst X was privvy to information released 
by the company -- allowing his company's favored clients to exit the stock 
in advance of public disclosure. I am very surprised to learn that this 
practice is not outlawed already under "inside information" trading laws, 
and recommed that you put a stop to this practice immediately.
     
Personally, I download and read all earnings reports, 10ks, 10qs and so on, 
and do not feel that an analyst brings any value to my investment decisions 
-- apart from inside information, of course.
     
Sincerely,
     
Richard Forsythe
Private Investor

     
	 

Author:  "Jeff and Raelyne Fieldsend"  at Internet
Date:    04/20/2000  7:58 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I'm tired of hand fed "analysts" getting advanced notice on company news, 
either good or bad.  Make it fair.
Rod Fredrickson
14020 113th Ave. Ct. East
Puyallup,WA 98374
e-mail=sirrodf@yahoo.com
	 

http://www.sec.gov/rules/0420b01w.htm


Modified:04/27/2000