Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Tom Barrett at Internet
Date: 04/23/2000 5:15 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To the SEC:
I would like to register my own comments regarding the above proposed
rule. I think the rule is a good one and should definitely be
implemented. The very idea of the SIA defending the position that a
small group of industry analysts should have access to better quality
information than individual investors (who are after all part owners of
the companies in which they hold shares) is repugnant to all ideas of
fair play in the securities market place.
The SIA, in its filing of April 6th, suggests that industry analysts
play a crucial role in the market, digesting information for the
individual investor, and that "the alternative model of millions of
individual investors and potential investors poring over prospectuses
and periodic reports is highly theoretical and out of sync with the real
world". I take issue with this assertion--I listen to conference calls
(on the Internet) of the companies I am invested in, I read their 10K's
and 10Q's. I feel that this statement by the SIA is merely an attempt
to preserve the "priviledged" position of its analysts.
The SIA further asserts that the work performed by analysts "results in
more continuous disclosure, fewer surprises and less volatility". I
would point out to you that, toward the end of last year, an analyst-set
price target of $1000/share resulted in a gain of 150 points in a single
day for Qualcomm (QCOM). The company's shares peaked at around $800 per
share and are now trading at a split adjusted $436 per share, having
returned to a more realistic valuation. It is difficult for me to see
how analyst activity contributed to "less volatility" in this case.
Please keep in mind that the owners of corporations (that is, the
individual investors who hold shares in them) deserve at least the same
quality of information as those industry insiders who make a career of
analyzing the corporation. An owner (shareholder) has far more at stake
than an industry analyst.
Thank you for your consideration,
Thomas Barrett
Individual Investor
Author: at Internet
Date: 04/23/2000 6:48 PM
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TO: RULE-COMMENTS at 03SEC
Subject: I have a right to know
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I want to know the information at the same time as everyone. I don't
want to be
the last one to buy or sell. It is something like insider information
when only a
certain few know in advance of what is to come.
I don't want an elite few to think that they only are smart enough to
decipher the
information.
Maurice Beaulieu
Author: Angeline Bell at Internet
Date: 04/23/2000 5:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No S7-31-99"
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What planet is the SIA from? And do they believe that analysts are of
some superior species than just regular men? This is one of the most
ludicrous proposals I have ever read!!
Angeline Bell
Author: "clayb" at Internet
Date: 04/23/2000 8:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD File# S7-31-99
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Information concerning all companies should be disclosed to all potential (and
current) investors not just a select few who will filter this information.
The directors of a company attempting to "spin" information would be reflected
in the market place.
Being forced to go to a select few individual for their spin on a company
(therefore delaying information to company owners and potential owners) is not
justifiable in today's age of instant communication.
Since I personally do not use a full brokerage house to buy and sell company
stock this places me at a disadvantage that can and should be eliminated.
Thank you for reviewing my comments.
Clayton V. Bonnough
5374 Antelope Lane
Stone Mountain, Georgia 30087
Author: "adboxjr" at Internet
Date: 04/23/2000 2:40 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC,
I can't believe this isn't already a law. Even for you guys this is a
No-brainer, especially with all the insider trade scandals that have taken
place over the last few years. Lets face it, the professional Wall Street
trader image has gone the way of the politician, straight down the tubes.
Protect us from ourselves? HA. The select few who will actually dig all this
stuff up, deserve it. For the most part most of the rest of us will continue
doing our business the way we always have. Dollar cost averaging, who cares
when the market crashes or soars, because I control nothing except my own
investment dollar amount.
Go ahead, do the right thing. Or does Wall Street pay your salary.
Douglas Box
US citizen (upper middle class)
Avid Foolish reader
Author: at Internet
Date: 04/23/2000 6:59 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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The current rule of allowing a small group of people, no matter who they are,
to receive prior information is a disgrace and should not be permitted. There
should be equal opportunity to hear information and not to just a privileged
few.
Obviously, this will be opposed by the securities industries for they have
nothing to gain by losing an immoral advantage It is things like this that
help create the deep cynicism about the government and its agencies that
pervades the country today.
Let the sunshine in. Let the analysts work for their information like everyone
else and do not allow the financial community any more early opportunities to
take advantage of others. Companies should not be able give financial favors
and have the opportunity to favor certain individuals and analysts and their
companies.
The reform is long overdue.
Harold Calder
6 High Pine Ave, Unit I
Nashua, NH 03063
Author: at Internet
Date: 04/23/2000 5:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am one of those "out of sync with the real world" individual investors that
the analysts want to keep further out of the financial information loop by
promoting this new regulation. I am appalled (but not surprised) that the SIA
is lobbying so heavily to continue, if not heighten, the secret flow of
information from publicly-traded companies to analysts. Especially when they
base their arguments on ideas like "analysts make the market less volatile".
What about the reaction to Abby Joseph Cohen's remarks just a few weeks ago?
That wasn't volatilty??? Bah.
The analysts and the stock brokerages they represent are just peeved because
their commissions are down due to discount investing and the dawning
awareness of the masses (like me) that they aren't nearly as successful in
making money for their clients as we were once led to believe. Sour grapes
on their part. Don't punish me because their profit margins aren't high
enough. This country and our capitalistic system is based on freedom of
information...let freedom ring!
Mona Calvert
Author: "Campbell" at Internet
Date: 04/23/2000 7:49 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Thanks for this much needed proposal!! Every investor I know (myself included)
is STRONGLY IN FAVOR OF FAIR DISCLOSURE OF INFORMATION TO THE PUBLIC BY
PUBLICLY TRADED COMPANIES. We want and need this information. It's the right
thing to do and good for the economy.
Thanks for your help.
Sincerely,
Nita Campbell
Author: "Sandi Campbell" at Internet
Date: 04/23/2000 5:05 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD File # A7-31-99
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It has been my observations that analysts already put their own "spin" on news.
I have also observed how often they are wrong in their analysis.
Therefore, I support regulations that would allow John Q. Public the same access
as the glorified analysts.
Sandra P. Campbell
7602 Browerdale Rd.
Siler City, N.C. 27344
Author: Geoff Chase at Internet
Date: 04/23/2000 12:19 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Re: Proposed Regulation FD: File No. S7-31-99
I would like to file my comments regarding rules
requiring equal and full disclosure to all holders, in
place of rules that allow selective disclosure to
analysts. Simply, selective disclosure should not only
be banned, but, the harshest possible penalties put in
place for those companies which disclose selectively
as well as those those firms, brokerages, or analysts
who receive that selective information. This approach
effectively treats such information as stolen
property.
The idea that a select group should be privy to
information not available to all shareholders allows a
select group the opportunity to profit, excessively,
at the expense of individual stockholders. Selective
disclosure creates an inherently biased system in
which for-profit organizations profit at the expense
of the individual investor. As a result, brokerage
firms can hold individual investors hostage to an
effective form of blackmail ("pay for my services or
suffer the consequences of my better information"),
and effectively creates a federally organized cartel
which profits at the expense of individuals. The SEC's
first and foremost mandate should be ensuring a level
playing field. Selective disclosure guarantees just
the opposite.
It can be argued that selective disclosure is
necessary since not all stockholders can be informed
at a single time. I would argue that the internet and
other public media such as daily newspapers provide a
forum for ensuring that information is available to
all. I think this argument is simply a sham attempt to
maintain a system that allows analysts and the
brokerages they work for to ensure profits they might
not otherwise be able to obtain, by maintaining a
biased trading arena.
This country is founded on the ideals of freedom of
speech and the free flow of ideas, which is
essentially the free flow of information unhindered by
secret processes. Hence, for the reasons above and
this basic argument, selective disclosure should be
outlawed. I would, with my vote support any candidate
or voter iniative that guarantees my right to the same
information currently only made secretly available to
a select few.
Regards,
J. Geoffrey Chase, Palo Alto, California
Individual Investor
=====
Geoff Chase
Email: geoffchase@yahoo.com
Phone: (650) 493-2585
Author: "Charles Chesnutt" at Internet
Date: 04/23/2000 4:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Full Disclosure Rule
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Dear SEC:
I strongly urge you to pass the regulation requiring full disclosure of
companies to the public. I am an attorney, and most of my friends are
well-educated and intelligent people.
As baby-boomers we are just starting to invest, forming and joining Investment
Clubs. We are learning, as the Beardstown Ladies did, that we can do it. We do
our own research, and have been very successful. We do not want analysts
telling us what they think about events. We make good decisions and are
developing our judgment and analytical skills.
My husband and I do research on companies using many different sources, and we
would very much appreciate your requiring management to disclose all relevant
facts to us. We already pore over Yearly Reports, and call management
personally when possible.
Thank you for considering our needs.
Carolyn Chesnutt, Attorney at Law, Dallas Texas.
Author: "D Cooke" at Internet
Date: 04/23/2000 4:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it concerns,
I am STUNNED that the proposed regulation is not already law. As a citizen
of the United States of America I have come to believe in democracy as well
as fair and equal opportunity. Who in this nation could seriously consider
any other alternative? Folks this is a bare-bones constitutional level
issue. This is about fairness and equal access to information.
Because retail brokers are compensated based on the number of trades that
they make, their researchers are under intense pressure to publish new
opinions on the public companies in the industries they follow. Opinions
create trades. The odd downgrade from strong buy to buy (huh?), the absurd
upgrade from sell to hold (think about that one), the layering of grays --
accumulate, market outperform, market perform -- let's first recognize that
each of these ratings creates a tradable event for brokers at the firm.
Until Wall Street starts taking responsibility for its public
recommendations, how can the individual investor ever trust the any analyst
or broker? Until we get a public account of these recommendations, analyst
by analyst, how can we be expected NOT to believe that a primary reason for
their being research analysts is to generate more transaction events and
trading commissions for their firms???
Please accept my support (and moral outrage that any other alternative has
ever been considered) for the Proposed Regulation FD.
Sincerely
Daniel Cooke
Author: Vince Coyner at Internet
Date: 04/23/2000 8:54 PM
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TO: RULE-COMMENTS at 03SEC
CC: tmfmax@aol.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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I believe this regulation pertaining to corporate disclosure (S7-31-99)
is essentially a good one. Although it would likely result in some
greater volatility in the short run, I believe that given all of the
pertinent data available, most active investors will make prudent
decisions. That does not mean that they will not lose money, it simply
means that they will be given the opportunity to make a rational
decision as a fully informed investor.
For investors who are not knowledgeable about the subject matter it will
likely not have a great deal if impact. These passive investors already
leave many of their investment decisions to professionals such as mutual
fund managers or financial advisors.
Regardless the level of investor, full and direct disclosure can only
make the markets more transparent and therefore more efficient.
Thank you,
Vince Coyner
Author: "CRAWFORD" at Internet
Date: 04/23/2000 7:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am writing to urge that the regulation be passed that would prohibit publicly
traded companies from discreetly giving analysts important, and pertinent
information, in advance of common shareholders, and the general public knowing
of such.
This, as well as other dynamics of the corporate-analyst relationship, are
unfair and cost individual investors money.
Thank you for your attention to this matter and for hearing my opinion.
Sincerely,
Jeff D. Crawford
117 Indian Trace
Chatsworth Georgia 30705
ph. 706-277-2049 x.102
Author: "clint" at Internet
Date: 04/23/2000 8:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I strongly disagree with the proposed regulation. Adoption of such restrictions
are not beneficial to the small investor and serve only to the advantage to the
large "Street" firms..
Clinton L. DesRosier
Author: Sanjay Dhamankar at Internet
Date: 04/23/2000 1:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the above proposed regulation.
--
*****************************************************************
* Sanjay Dhamankar * OMNIMA Systems, Inc. *
* sanjay@omnima.com * http://www.omnima.com *
* Tel / Fax : (408) 736 5839 * info@omnima.com *
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* Java/Internet, OOA/OOD, C++, GUI, UNIX/NT/Windows Solutions *
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Author: at Internet
Date: 04/23/2000 3:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD, File No. S7-31-99
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Ladies and Gentlemen:
I fully support the general thrust of your proposed rule. As with any
significant rulemaking, significant difficulties surface in the details of
implemention. In that regard, the National Investor Relations Institute
(with which I am NOT affiliated) has raised some reasonable concerns in their
comments (April 11, 2000) on the proposed rule. I urge you to give serious
consideration to their comments.
Thank you for the opportunity to comment on this rule.
John D. Evans
Individual Investor
Montgomery Village, Maryland
Author: "Matthew J. Evans" at Internet
Date: 04/23/2000 3:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor, I SUPPORT proposed rule S7-31-99,
"Selective Disclosure and Insider Trading."
Selective disclosure is contrary to the intentions of a free market
in a free country.
Matthew J. Evans
Author: Mike and Nati at Internet
Date: 04/23/2000 7:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: I can make my own decisions - Mike Ginsburg
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The FD rule is a good one in my opinion. I would prefer to receive
financial information when it is public. By public, I'm talking about
the general public, not the private public of analysts as the SIA
prescribes.
The SIA comments are based on the unfounded assumption that people
cannot perform their own analysis or make their own decisions.
I for one have had better returns than over 80% of all mutual funds over
the past few years. These mutual funds are run by the same analysts
that the SIA confers superior intellectual powers to. Yet, they can't
beat the average market return (S&P 500).
Let me make my own decisions and suffer my own consequences.
Thank you,
Mike Ginsburg
Author: "Jack L Harlan-Marriott" at Internet
Date: 04/23/2000 8:21 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor I would like to see information disclosed to
all...not just the big guys.. We deserve the same information - NOT "as it is
now" (ie, later),
but at the same time as they get it.
Jack L Harlan-Marriott
Author: Subodh Harmalkar at Internet
Date: 04/23/2000 8:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File No. S7-31-99"
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I am an individual investor.
I feel that a company that I invest in *must* disclose
whatever it divulges to public through Internet and any
such medium which makes the information
highly available to every possible investor.
You may want to consider following things:
1. Fines for departure from such behaviour
2. Establishing SEC site as the final resource
rather than the company web-site.
For news-letters/analysts which try to publish
their reccomendations please consider following
suggestion:
1. Make the analysts sumbit a true record
of their suggestions (buy/sell) vs. the
actual performance. And force that
industry to create such a web-site/something
where individual investor can verify prior claims.
Subodh
Author: "Jeff Harvey" at Internet
Date: 04/23/2000 1:08 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I HIGHLY support this proposed rule. I have always been very disturbed
that analysts and Wall Street insiders get access to company information
before the general public does. This has always struck me as "insider"
information and definitely tilted the playing field toward analysts and
Wall Street brokerage firms, to the detriment of the individual investor.
I have also read Wall Street's response to the proposed regulation and
was quite disgusted and dismayed by it. What they are saying is, "the
individual investor is too stupid to interpret information from the company.
They need the analyses from 'trained analysts' in order to correctly
interpret this information." I say, HOGWASH! The analysts have always
had an unfair advantage over the individual investor and they are just
trying to protect their (rapidly shrinking, thankfully) turf.
I STRONGLY urge to you adopt this proposed regulation.
Sincerely,
Jeff Harvey
harvey@pacbell.net
Author: "DONNA HEWITT" at Internet
Date: 04/22/2000 4:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Yes to Proposed Regulation FD.
James Hewitt
Author: at Internet
Date: 04/23/2000 2:15 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Its absolutely ridiculous the government continues to condone the legal
insider-like environment private trading firms enjoy in obtaining and
utilizing closely held corporate information for their own benefit. This
practice reeks of discrimination and cronyism, and allows the private
firms to take advantage of the common public that is being played the
poor fools in the situation. When those giant corporate firms make that
outrageous excessive profit from that "inside" information, where do you
think that profit came from? They suckered it away from the general
public through this practice of legal manipulation; the same general
public that is the constituent body of this great country.
Its high time the elected officials of this great country step forward
and eliminate this con game being played on the public. This regulation
is way past due.
Thank you for your consideration.
Sincerely,
Rick Hoddinott
369 Entler Ave.
Chico, CA 95928
Author: Jerry Hougen at Internet
Date: 04/23/2000 4:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I do not agree that analysts make the market less volatile. If anything
they start all of the runs and routs that are happening these days. I
had a stock run up (60 Points) a few months ago on some analysts words
only to fall back to its starting point a few days later based on
reality, the only ones benefiting there are the short term investors and
the analysts buddies.
The only way to play fair in the stock market is to give all the people
the same information at the same time. Analysts add very little, if
anything to discovering the true value of a company in the stock market
or the world. The only thing worse would be if the media was brought in
first to interperate a companies release.
Please pass rules that level the playing field.
Thank you,
Jerry Hougen
Small Investor
Author: Harris Jacobs at Internet
Date: 04/23/2000 9:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support full disclosure to the public rather than just to analysts. I make
investment decisions based only on my own research. I don't believe that
analysts should have earlier access to information that is important to me.
This information should be fairly provided to the general public at the same
time as it is given to the analysts!!!
Harris C. Jacobs, MD
Yale University
Author: at Internet
Date: 04/23/2000 8:15 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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I support passage of the above listed regulation.
Bob Johnson, individual investor.
Author: "brijones" at Internet
Date: 04/23/2000 4:17 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: No. S7-31-99
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To. The Ad Hoc Working Group on Proposed Regulation FD April 23 2000
I was very encouraged to read about your consideration of Proposed Regulation FD
S7-31-99.
As a small individual investor as I read about it my first thoughts were this is
going to be tough to
enact, as the special interest groups will fight it tooth and nail.
We are all familiar with the expression "the pig is not dead" when it comes to
Wall Street they seem to fortify the expression every day.
This legislation will greatly enhance the ability of the intelligent present day
investors to stay informed with current information and help them with their
investment decisions.
I will end with please don't take into consideration the lame reasoning of the
SIA that we can't read prospectus and quarterly reports and make our own
decisions.
They are not concerned with our welfare only there own.
Sincerely
Brian W Jones
418 Windy Woods Way
Fountain Inn, SC 29644-9222
(864) 862-7363) brijones@gateway.net
Author: "Mar Del Sud; Ltd." at Internet
Date: 04/23/2000 11:47 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir:
After reading the response of The Ad Hoc Working Group on Proposed
Regulation FD and the Legal and Compliance Division of the Securities Industry
Association (SIA) to the proposed regulation FD: File No. S7-31-99, the
following thought stuck in my mind:
It seems to me that in todays market, analysts have the power to
drive up or deflat stocks on a huge scale just by making comments. This has
happened time and time again. Analysts have the ability and power to manipulate
the market. I think that this power has come into play in the last few years.
Maybe if information was not keep limited to a select few, the power
to manipulate the market would be diminished.
An Individual Investor
Charlie King
Author: Bobby Kochhar at Internet
Date: 04/23/2000 3:18 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am all for complete disclosure to the public as well
as the analysts. The analyst's job is to ANALYZE given
data. Its not to act on priveleged information which
has been denied to the individual investor.
Bobby Kochhar
Santa Clara, CA
Author: "Chang LI" at Internet
Date: 04/23/2000 6:32 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor I support the following rule:
"The rule (Proposed Regulation FD) would require, among other things, that
companies no longer engage in the practice of discreetly disclosing
important information to Wall Street analysts without also giving that
information to the public at large."
Chang LI
changl@neatware.com
Author: at Internet
Date: 04/23/2000 4:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Chairman Levitt,
Once again I applaud you and the SEC for the Proposed Regulation FD:
File No. S7-31-99. The SIA lobbying effort should not construed as
being in the bes interest of the American public.
The SIA claims individual investors are incapable of investing on their
own. Please remember that the Vanguard S&P 500 Index Fund is the largest
mutual fund, and yet the vast majority of the so-called experts who the
SIA supports do not beat the S&P 500 index in their own recommendations
to consumers. Of the thousands of mutual funds and brokerage recommended
portfolios 85% to 90% fail to beat the S&P 500 index. The individual
investor can beat the vast majority of mutual funds and portfolios
recommended by Wall Street analysts just by investing in a stock index
mutual fund. The claims of the SIA are completely wrong and are intended
only to thwart the individual investor in order to seek unfair profits
from the outrageous commissions they charge.
With the technology available today, and at minimum price, full
disclosure of inside information can be done for the public, as well as
the so-called expert Wall Street analysts (remember those portfolios
that underperform the S&P 500 index?). Many companies, such as Intel,
already do this. The conference call is available on the internet and
available to everybody.
Please support the American people and adopt the Proposed Regulation FD:
File No. S7-31-99. Do the right thing for America and the average Joe,
and ignore the lobbying efforts of the so-called Wall Street analysts and
their underperforming mutual funds and portfolios with outrageous
commissions.
Taylor E. Mack
Mississippi State, Mississippi
Author: at Internet
Date: 04/23/2000 5:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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It is absurd to believe "a chosen few" should be privy to information which
is of interest to all investors.
I believe Thomas Jefferson had a few things to say on a related topic.
Regards
Steven H Mackelprang
Author: "William Mahoney" at Internet
Date: 04/23/2000 8:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject:
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I am not convinced that "analysts perform a necessary and valuable function in
the U.S. capital markets"? I independently research stocks using public
information as well as publicly available analysts comments. I do not think the
"model of millions of individual investors and potential investors poring over
prospectuses and periodic reports is highly theoretical and out of sync with the
real world", in fact I think it is today's real world. I find it a bit
disingenuous to maintain that "analysts make the markets less volatile", in fact
I have read a number of analysts commentaries that maintain the markets are less
volatile because so many individuals invest and do not react so extremely or
rapidly as do institutional investors. I hope that you will support individual
investors, the population that needs your support much more than the
professional analysts, by requiring , among other things, that companies no
longer engage in the practice of discreetly disclosing important information to
Wall Street analysts without also giving that information to the public at
large.
Bill Mahoney
Author: Michelle Matel at Internet
Date: 04/23/2000 2:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the proposed SEC regulation prohibiting
selective disclosure of information by publicly-traded
companies. I feel that allowing dissemination of
information to a subset of analysts creates incentives
for those analysts to consider the effect their "take"
on the information will have on the relationship with
the companies. This may have led to biased or
incomplete commentary and/or recommendations by those
analysts. Further, individual investors, or analysts
known to engage in investigative study, do not receive
information in a timely manner, leading to
inefficiencies in the market. Sincerely, Michelle Matel
(no business affiliation)
Author: james mcgowan at Internet
Date: 04/23/2000 1:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: jamcgow@ibm.net at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I would like to express my strong support for the proposed regulation.
One of the most valuable contributions the United States Government,
through the SEC, has made to the American economy has been the steps it
has taken increase full and timely disclosure of relevant information by
corporations. That is also, at heart, the reason why so many foreign
nationals have been willing to acquire stocks of American companies. They
can know what they are getting and have reasonable assurance that vital
information is not being withheld or falsified.
The Securities Industries Association has stated its opposition to the
regulation. This is understandable; no clique likes having its
privileges withdrawn. Yet the very reason they oppose it- -that it
would allow everyone access to the same information at the same time-
-is the reason it should be adopted.
The SIA states that meetings between analysts and companies would become
less common or cease. That might be, but if the effect is to prevent
improper disclosure of inside information to underwriters and brokers,
then a positive result has been achieved.
Companies are always willing to publicize positive information. That
would not change because of this; this regulation would simply mean that
this information would be immediately publicly available rather than
being closely held by Wall Street insiders until it was convenient and
profitable for them to publicize it.
Negative information is always a stepchild. The current legal has made
it more hazardous for corporate insiders to attempt to hide negatives.
When they feel they must disclose it, there is no good reason that an
analyst should be told sooner than the public.
The SIA claims that
"The alternative model of millions of individual investors and potential
investors poring over prospectuses and periodic reports is highly
theoretical and out of sync with the real world."
That may be true of their customers, but it is not true of me or many
other individual investors. I have accessed the SEC's archives many
times and consider them a valuable resource. Those investors who wish
to be spoon-fed their information and opinions be underwriters and
brokerages can continue to do so; this regulation will do nothing to
prevent that.
James R. McGowan
1508 Harrison Ct.
Sunnyvale, CA 94087
jamcgow@ibm.net
Author: "rsm" at Internet
Date: 04/23/2000 6:54 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD: file # S7-31-99
------------------------------- Message Contents
Please respect our rights as individual stock holders to buy and sell. We
respect the professionals in the Stock Market, but resent them getting
information before the general public hears about any pertinent facts that would
also be to our advantage.
I'd appreciate your interest in this matter.
Thanks very much Joye Megow
Author: at Internet
Date: 04/23/2000 7:38 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Information about publicly traded companies should be open to the rePUBLIC in
the same time frame as it is given to those currently controlling these
issues.
Curtis H. Noland Jr.
Riverdale, MD- 20737
Author: "Richard Patteson" at Internet
Date: 04/23/2000 4:56 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-31-99
------------------------------- Message Contents
Date: April 23, 2000
Subject: File No. S7-31-99
Dear SEC,
Thank you, as a new investor, for this opportunity to comment on the "Proposed
Regulation FD File No. S7-31-99".
If it had not been for the wealth of "free" information offered by the Internet
and Media I would never had taken that first step.
The market has become more accessible. As it should and Fair Disclosure is
essentially a vital tool, to help us work this growing accessibility.
Preserving selective disclosures is simply bad for business and the Market.
Richard Patteson
Individual Investor
Author: "Scott Pollard" at Internet
Date: 04/23/2000 4:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To whom it may concern,
A monopoly of information is not conducive to competiveness. I would like
to add my vote to any rule that allows the individual investor the same
access to information that the brokerage analysts have.
Thank you,
Scott Pollard
Author: Hector Ramirez at Internet
Date: 04/23/2000 8:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I fully support full disclosure to all investors, from publicly traded
companies.
Hector Ramirez
Author: Greg Satfield at Internet
Date: 04/23/2000 7:47 PM
Normal
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 guess I am one of those mindless non thinking investors that the
industry speaks about. However when the mutual fund manager of 85% of
the mutual funds can not even match a passive index fund it leads me to
think you are trying to "protect" the wrong people.
I can read company reports, get information from Edgar, get information
on-line from companies and a host of other informative things that let
me make informed decisions on my own with the advice or BS of the
analysts.
By the way, last year my wife & I were up 73% for the year without any
advice from the industry experts. I guess we were just lucky!
When you put in your study time and use what is between your ears for
more than a hat rack you can do great things.
I am against keeping information for the "privileged" few. Accurate and
open disclosure is the best way in a free society.
Thanks for your time,
Greg Satfield
Greg Satfield
4812 Emerald Drive East
Mobile, Alabama 36619-1446
Author: at Internet
Date: 04/23/2000 6:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Ladies and Gentlemen:
The April 6, 2000 comments by the Ad Hoc Working Group on Proposed Regulation
FD and the Legal and Compliance Division of the Securities Industry
Association is full of arrogance vis-a-vis the individual investor. Their
points are not well taken by this individual investor.
I think the commission should proceed with Regulation FD at the end of the
comment period.
Manfred B. Schmidt
104 Mallow Hill Road
Baltimore MD 21229-3122
Author: "Mike Shamel" at Internet
Date: 04/23/2000 5:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I for one support Proposed Regulation FD. How can full disclosure, NOT be
good for the US securities industry. To argue otherwise smacks of elitism
and institutional arrogance. Lets level the playing field. Give me access
to the same raw information institutional analysis receive. If we are truly
dealing in PUBLIC information, I deserve the right to process the
information using my own resources, and in the same timeframe as for-profit
institutions do.
================================================
Mike Shamel Phone 410-654-3796
10859 Sherwood Hill Road mshamel@home.com
Owings Mills, MD 21117 http://members.home.net/mshamel/
Author: "Elizabeth Smallwood" at Internet
Date: 04/23/2000 8:12 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Companies need to disclose important information to the public at large and not
just to Wall Street analysts. This kind of full disclosure should already have
been put into place years ago. It is shocking and unbelievable that it has not
already been done.
Author: "mark r. steineke" at Internet
Date: 04/23/2000 5:35 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Open the rule for fair disclosure of information on public traded companies
to the public..
Mark Steineke
Author: "John M. Stock" at Internet
Date: 04/23/2000 8:05 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs,
I would like you to know that I am in favor of Proposed Regulation FD: File
No. S7-31-99. As an individual investor, I feel that availability of all
information to the public is crucial to our ability to do due diligence in the
investigation of which securities we wish to invest in. I believe that the
public is "smart enough" to be able to evaluate & digest such information.
I also feel that any other method creates a playing field biased towards
large instututions, which, in the long run, will discourage individuals who
wish to invest.
John M. Stock
jstock@stlnet.com
Author: Wayne Wilcoxon at Internet
Date: 04/23/2000 12:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Instead of spending piles of money for a lawyer to write a 40 page
"note" I thought that as an individual investor with limited funds, I
would speak my mind as such, in a short note.
I feel that the information should be available to all people
(individuals, institutions, analyst, corporation and media) at the same
time, for reasons of fairness. If that information causes the price of
the stock to move radically either up or down because of the news, so be
it. That is the principal that this country lives by "FREE ENTERPRISE"
Timely information means different things for different people, for me
that might mean that I can receive the information by E-mail or
searching for it on the internet, after I get home from work at the end
of the day. For others it might mean receiving the information the
instant it is released to the public. Still other might be happy to
receive that same information from their broker via phone call in a day
or two, or even Snail-mail (letter) within a week or two, or even slower
such as some newsletters that arrive two or three months later. With the
proposed rule change, it will make the "Freedom of Choice" more of a
reality.
With regards to the information being released by the company to me as
an individual, I feel it gives me more control over how and when I use
it and interpret it. If I have a working knowledge of the stock market I
might use that info immediately. If I have questions or concerns I might
ask someone for assistance or contact my broke for advice, which ever I
feel comfortable with, at least I would have a chance to make the
decision mine, in a timely manner.
Thank you for listening.
Wayne Wilcoxon
7620 W. Lockland Ct.
Peoria, AZ 85382
Author: "DJW" at Internet
Date: 04/23/2000 1:46 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I support the rule (Proposed Regulation FD) that would require companies to no
longer engage in the practice of discreetly disclosing important information to
Wall Street analysts without also giving that information to the public at
large. Private disclosure by public companies is unfair to the market as a
whole. It puts the individual investor at a illegal disadvantage to the
fat-cats on Wall Street.
Dave Wolfson
Individual Investor
Author: "RICHARD WYMAN" at Internet
Date: 04/23/2000 1:57 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Change rulings, and give the investor the opportunity to make there own
decisions.
Don't let the rich get richer off of insider information, and the poor get
poorer off of what they want to tell us.
Open markets up to the freedom of choice as well as the freedom of markup in
the price of stock.
Rick Wyman
rikyrich@hotmail.com
Author: at Internet
Date: 04/23/2000 3:51 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Newrule about disclosure of info to analysts
------------------------------- Message Contents
I bekieve any disclosures by a company should go to all,not just analysts. As
you probably know many analysts work for individual brokerage houses and
unless you have a broker handling your account who is willing and able to
goive you the analsts opinion you are not going to get it.Furthermore if one
is attempting to follow the advice of Ben Graham this information is
paramount th have before investing..ken zeigler
http://www.sec.gov/rules/0423b01.htm
