Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Ashmore Todd at Internet
Date: 04/24/2000 9:59 AM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: RE: Proposed Regulation FD: File No. S7-31-99
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I am responding to the current issue of proposed regulation FD. If the
"markets" are truly free markets then ALL investors get the SAME information
at the SAME time. I support Regulation FD as I am my own analyst and do not
need people (who apparently feel that they are smarter than the average
American) getting better information, faster than the small investor. For
them to claim that they serve a purpose for me is ridiculous. These Wall
Street "power analysts" do not have the same investment horizon, risk
profile or general opinion that I do, so how do they serve any purpose for
me.
Level the playing field.....approve Regulation FD.
Todd Ashmore
Washington, PA 15301
Author: at Internet
Date: 04/24/2000 9:06 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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I FIRMLY BELIEVE THAT THE PUBLIC SHOULD BE INFORMED AND LET US MAKE THE
DECISIONS, NOT SOMEONE FOR US.
Respectfully,
William Barnard
A Schwab Investor.
Billinvestor@aol.com
Author: "Sean T Barron" at Internet
Date: 04/24/2000 7:35 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support equal information for everyone.
Sean Barron
Author: Bill at Internet
Date: 04/24/2000 8:32 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am a significant taxpayer and securities investor. I feel that to
restrict information and release it preferentially to analysts first is
a monopolistic practice that results in unfair competition.
If the market is to be efficient in setting the real value of
securities, there must be a free flow of information. If insider trading
is illegal, so should be restriction of information to analysts. There
is no difference, in my mind, between the two situations of trading on
information restricted from the public.
William Beall.
Author: "Curtis A. Bolden" at Internet
Date: 04/24/2000 9:18 AM
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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 may concern:
Having read some of the arguments regarding the "Proposed Regulation FD:
File No. S7-31-99", I do not support the Bill and would urge all involved
to vote "no".
Signed,
Curtis A. Bolden, voter and investor
Author: at Internet
Date: 04/24/2000 9:34 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Democratization of information
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Dear SEC:
I write to support the adoption of your proposed regulation FD. Surely you
will want to be on the right side of history on this one.
Sincerely,
Foster Davis
Author: "C.Patrick DeLany" at Internet
Date: 04/24/2000 8:03 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
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April 24, 2000
Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549
Re: Proposed Regulation FD, File No. S7-31-99
Dear Mr. Katz:
As a private citizen and investor, I support the SEC's objective of
eliminating selective disclosure.
C. Patrick DeLany
Author: dondix at Internet
Date: 04/24/2000 12:11 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Sirs:
Upon reviewing Regulation FD and a number of the factors surrounding this
proposed regulation, I am convinced of several things:
1. This regulation does not prohibit analysts from conducting the same type of
analysis they currently do, it only adds to the number of eyes that have the
opportunity to review.
2. Clearly, most of the public that certain people seem to want to protect,
aren't even going to know what to do with the information in front of them.
3. Any information about public companies is and should be public. Remember,
it has been proven over and over again, that in a "free market", A RISING TIDE
LIFTS ALL SHIPS.
PASS THIS REGULATION.
Respectfully,
Donald Dix
Author: Nick Fallows at Internet
Date: 04/24/2000 2:05 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 express my support for full disclosure.
Nick Fallows
Author: Mike Gilronan at Internet
Date: 04/24/2000 6:57 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 or Madam:
I am writing today in favor of the Proposed Regulation because I feel that
fair access to information will make financial markets less volatile and
more efficient. If certain analysts today get out ahead of the market at
large because of access to management not granted to the public at large, I
believe that a disservice is thereby done to the pubic. If all information
provided to analysts is concurrently provided to the public at large under
this rule, the public can then decide whether to pore over prospectuses and
financial reports on their own or avail themselves of the counsel of
analysts who can more effectively read the tea leaves due to exhaustive
technical analysis, depth of expertise in an industry or sector, etc.
I agree that it is important, as detailed in the SIA filing, that analysts
should continue to have the ability to ask pointed questions of management,
and to follow up on those questions to "dig" a bit on difficult issues, but
the availability of that dialogue to the investing public at large (as in
the case of a CEO presentation on a network such as CNBC) is important --
the access to management is provided as a service to the investing public,
not merely to the community of analysts.
Best regards,
Mike Gilronan
Project Manager
ePartners, Incorporated (formerly TexSYS RD)
125 Nagog Park
Acton, MA 01720
ph: 978.206.2270 (office)
fax: 978.266.8976
e-mail: mgilronan@epartnersolutions.com
http://www.epartnersolutions.com
Author: "Vicki Gordon/ Ron Weintraub" at Internet
Date: 04/24/2000 12:19 AM
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TO: RULE-COMMENTS at 03SEC
Subject: RES7-31-99
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I am an individual investor who manages my own portfolio. I have been doing
this since the mid 1980's. My returns usually match some of the industry
leaders for balanced portfolios in the mutual fund industry.
My investments have grown and I perform a lot of due diligence. I regularly
read both wall street papers, Electronic news, The Wall Street Transcript,
Forbes and other publications.
Over the years the industry experts in finance always worry the small investor
will panic....far more often I see young fund managers panic as they worry about
NAV's, bonus checks , and keeping up with the "competition". None of which is
the basis for good investing. So I feel angry when it is implied that I cannot
handle information directly from the companies that I am investing in and
thereby own.
The less exclusive information that exists the more efficient and fair the
markets will be for all investors. No, I can't listen to every company call,
nor do I want to but I feel I should be able to get the information if I do want
as fast as any other investor. Now when a company is upgraded by an analyst I
must decide does he have inside information, or have I missed some obvious data,
or is there a crack in the Chinese Wall. At least if I am privy to all company
information then my decision making is a little easier.
Very truly yours,
Victoria J. Gordon MD, MBA
Author: Jim Goreham at Internet
Date: 04/24/2000 8:15 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No S7-31-99
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I would like to once again express my opinion on the value of the above rule
and the need for such rule.
Individual long term investors who research companies for investment do so
with a need for information which comes directly from the company which they
research. Current SEC rules require disclosure of certain risks of foward
looking statements and a recent annual report which I received was rife with
them. Those who are are patient and diligent enough to do the research
required to make stock purchasing decisions will benefit from Regulation FD.
Relying upon analyst's who may put a "spin" on a company report, for a
variety of reasons, is not in the best interest of many individual
investors.
I thank you for your consideration and urge passage of Regulation FD.
Thank You,
James T. Goreham
Individual Investor
Author: "Raffi Gostanian; Jr." at Internet
Date: 04/24/2000 8:31 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Open disclosure to all!
Raffi Gostanian, Jr.
McKinney, Texas 75070
Author: at Internet
Date: 04/24/2000 9:08 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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From: Bill Greer
E-mail: bill@cambertx.com
Date: 04/24/00
Time: 09:08:14
Please require that any information released to analysts is also released to the
general public. Like
most people I assumed that was already the law, and that anything else would
constitute insider
trading. The SEC should not be in the business of protecting the profits of big
brokerage houses, and
if you do not level the playing field of information disclosure that is what you
will be doing. I have
a lot of money invested, I do not want to be in the position of having to go to
one of these houses to
find out what the companies I have invested in are doing.
(signed)
William B Greer
6407 Garlinghouse Lane
Dallas, TX 75252
Author: "Haberlandt; William F. (LNG)" at Internet
Date: 04/24/2000 8:42 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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This is a great common sense rule and should be passed! "Inside" information
is a source of knowledge, power, and money and it is no surprise that the
SIA wants no changes at all!
The whole SIA and the media cause the churn and volatility in day-to-day
market moves making "news" out of nothing significant. The SIA's motivation?
Power - they alone have access to certain information. Money - making news
out of trivial information generates transaction revenues!
Please adopt the new rules!
Bill Haberlandt
1131 Mead Rd.
Bellbrook, OH 45305
Author: " G Haft" at Internet
Date: 04/24/2000 8:07 AM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed rule FD
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It has come to my attention that the proposed rule to require companies to
disclose information to the public is being being opposed by the analysts and
brokerage houses that benifit from the status quo. It is my opinion that the
rule should be put into place immediately to correct a wrong. It is wrong to
give information to some and not to others. As an individual investor I feel I
am entitled to the same information as anyone.
ghaft@dcwis.com
Author: "CAREY HAMBLETON" at Internet
Date: 04/24/2000 5:58 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD S7-31-99
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As best as I can understand this bill (?) it makes corps. disclose
information to the public and not just to a select few "brokers", etc..
Complete public disclosure is the key to a more productive economy, and it
is anti-american for the analysts to have better information than the
participants in the market.........thank you........
Author: David Harkreader at Internet
Date: 04/24/2000 9:07 AM
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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 open and equal communication
between corporations and the stockholders who invest in the companies. Please
require all company information presented to "analysts" to be available to the
public at the same time that is is available to the analysts.
Thank You
David Harkreader
Author: "Ron L. Helms" at Internet
Date: 04/24/2000 8:52 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please, do not protect us from ourselves as the security analysts would
have you do.
I am an individual investor, and able to make my own decisions. So are
most other investors. What we need is a level playing field. If
information is given to any investor or analyst, it should be available
to all potential investors (i.e., everybody). This is free flow of
information, and this would be the hallmark of an open and level playing
field for ALL market participants.
Please do not be fooled by the self-serving meanderings of the
Ad Hoc Working Group on Proposed Regulation FD and the Legal and
Compliance Division of the Securities Industry Association ("SIA")
They are just trying to protect their perks in the system as it is. If
they
perform a function, that function can just as well be fulfilled with
everyone having the same access to information as opposed to the elite
few having access to financial information.
In short, I am an inteligent adult. I can decide for myself how much
risk I can take in investing. I do not want someone filtering
information for me!!!
This is especially true if I cannot see the unadultarated information
first.
I am for passage of this bill.
--
Ron Helms Alcatel Network Systems
Tel: (919) 850-5461 Raleigh, N.C.
email: helmrl@aur.alcatel.com
homepage: http://aurwww.aur.alcatel.com/~helmrl/
"If a hoppy-toad had wings, he wouldn't bump his
butt as he goes hopping along."
Author: "Frank Hinds" at Internet
Date: 04/24/2000 3:28 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I strongly support this regulation. The current system of allowing analysts
firsthand information before the public smacks of insider knowledge and I
believe is against the code of ethics. All one has to do is examine the last
several months reporting from many of these analysts and it is easy to see
manipulation of the stock market.
I will be watching this vote closely. I urge you to adopt this regulation.
Frank Hinds
171 Central Street
Stoughton, Ma 02072
Author: "dave holsey" at Internet
Date: 04/24/2000 9:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reguation FD: File NO S7-31-99
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I believe it is in the public's best interest that the above reguation be
approved. David Holsey
Author: "Debbie Kirkland" at Internet
Date: 04/24/2000 4:35 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am in favor of the above rule. If a company is to be traded publicly,
it's information is public. Keeping public information secret or limiting
access to it is communistic!
The theory that I have to depend on analyst, spin doctors and the media for
proper interpretation of these reports is ludicrous. Most analyst are wrong
more than they are right and I learned several years ago not to depend on the
mainstream media.
If I don't have sense enough to intrepret the data properly, it's my problem
not someone else's. It's my money, not someone else's.
I repeat. Keeping public information secret or limiting access to it is
communistic!
Thank you,
Debbie Kirkland
Route 1 Box 209
Headland, AL 36345
334 693-2552
Author: dknoll at Internet
Date: 04/24/2000 9:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Regulatory comment FD
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Good Morning:
My comments are in reguard to proposed regulation FD which would require
publically traded companies no longer engage in the practice of
discreetly disclosing information to Wall Street analysts without also
releasing information to the public at large.
I stand in favor of this proposed regulation. Individual investors are
increasingly making investment decisions without the help or advice from
analysts or firms. It is common sense to disclose equally to all
investors. The arguments from the Securities Industries Association can
only be interpreted as a self serving position that investors require
their advice and input. Nothing could be further from the truth.
Let's level the playing field for all investors and end this unfair and
discriminatory practice.
Thank You.
Richard K. Knoll
2700 Burlingame Rd.
Topeka, KS 66611
dknoll@bigfoot.com
Author: Klaus Kretzschmar at Internet
Date: 04/24/2000 1:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir, Dear Madam,
I strongly support the proposed Regulation.
My main argument is: The early dissemination of company "news" to a
select few (analysts etc.) adds a delay line that is not beneficial to
the shareholder. The shareholder still has the choice to listen to what
an analyst has to say as one information channel.
In addition, the fact that most brokerage house employing analysts are
also market makers on Nasdaq presents a conflict of interest which could
be construed to facilitate insider trading.
Yours faithfully
Klaus Kretzschmar
Author: Deborah Lonrau at Internet
Date: 04/24/2000 3:35 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs:
I am writing to let you know, that as an individual investor, I strongly
SUPPORT the above proposed Securities and Exchange Commission rule
regarding the fair disclosure of information by publicly traded companies
to the public. 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. The current practices
result in reduction of the overall mix of information in the marketplace,
less accuracy in market prices, greater volatility and, in general, vastly
reduced efficiency. The unreasonable advantage supplied to the few is akin
to that of insider trading, and should have long since been ruled against.
Sincerely,
Deborah Lonrau
Author: "Timo Luege" at Internet
Date: 04/24/2000 10:52 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs,
I am foreign investor and as such I am not sure whether I am eligble to make
comments on the proposed regulations. But since I'm putting my own money
into US-companies I'll say what I think anyhow:
In my opinion it is grossly unfair that analysts and fund-managers, who are
not primarily putting their own money at risk, have an information-advantage
ver individual investors who actually do risk their own savings. Therefor I'm
very much in favour of levelling the field so that everyone interested in a
company has the same amount of access to information.
As for the SIA saying:
> It hardly needs saying that analysts perform a necessary and very valuable
> function in the U.S. capital market.
> They, together with the media, are the principal way in which important
> financially significant information (including information contained in
> prospectuses and reports filed with the Commission) effectively reaches
most
> investors and gets reflected in the marketplace. 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.
If the SIA really thinks that most investors will not read 10Qs and 10Ks than
they should not have a problem with the changed regulations at all. Because
all those people who are not interested in working their way through the SEC-
filings will still rely on the analysts and the media for guidance. But those
individual investors who are prepared to learn everything about the
companies they intent to invest in, are given a fair chance to obtain the
neccessary information. In my opinion the SIA is trying to hold on to its
privileges not because of worries about the individual investors financial
health but because they want to keep their information-monopoly. That, of
course, is understandable from their point of view. But I don't think it is
desireable from a regulatory point of view and definetely not from an
investors point of view.
With kind regards,
Timo Luege
Germany
Author: Warren Mahan at Internet
Date: 04/24/2000 10:04 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Fair Disclosure
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I like many small investors believe that any information released by a
publicly held company should NOT be released in advance to a few
analysts on Wall Street. This information should be made publicly
available at the same time to any interested party. Why should Wall
Street brokers continue to get richer off advanced information.
Put the Fair Disclosure rules into affect and watch the wise small
investor become more involved in the market.
Thanks for providing a place for the public to express their opinion.
Author: "Susan & Gerhard" at Internet
Date: 04/24/2000 4:10 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I fully support the proposed regulation. I am an individual investor, who
happens to additionally be a normal, hard working American. My investment
choices are made solely by myself. I use SEC filings; prospectuses and
periodic reports; and press releases and open conference calls as tools for
making my investment decisions - since I can be relatively assured that
through these sources I will be obtaining the facts and not conjecture about
a potential investment. Unfortunately, I feel the odds are stacked against
me.
How can I get a fair shake at an investment when information is withheld
from me just because I don't have the clout to conduct a series of telephone
conversations or face-to-face meetings with issuers. Why should information
given to analysts not be made public? I certainly can not believe that
individual investors with this type of information cause market
instability - on the contrary - big institutions who get this information
first do. The result being that the individual investor suffers the
consequences.
I am shocked and outraged by the public comments of April 6, 2000, by The Ad
Hoc Working Group on Proposed Regulation FD and the Legal and Compliance
Division of the Securities Industry Association. Since the SIA is the
principal lobbying outfit for the full-service brokerages it is no wonder
that they can write such an offensive text with concern to individual
investors intelligence.
For me, part of what America is about is justice and this proposal would be
justice for all.
Thank you,
Susan C. Marshall
Self-Employed Chemical Engineer
Author: "xswqaz" at Internet
Date: 04/24/2000 8:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support fair disclosure to everyone. Timmie McBride, individual investor
Author: at Internet
Date: 04/24/2000 6:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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We have to remember that we live in a democracy with a written constitution
giving us the power to vote. I'm not sure whether Proposed Regulation FD:
File No. S7-31-99 is even constitutional - only the courts, a long time,
money & angst will decide that. Meanwhile I strongly believe in freedom of
information for all stockholders - and that includes the opportunity to hear
news from a Company I "own" - albeit in very small part - at the same time as
the large institutional shareholder.
Please vote AGAINST Proposed Regulation FD: File No. S7-31-99.
Roddy McMullen
Author: "John C. Miller" at Internet
Date: 04/24/2000 7:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD and Securities Act Rule 181
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To Whom it may concern,
I am in favor of the proposed Regulation FD and Securities Act Rule 181.
Individual investors do not need Wall Street mavens to pre-digest information.
Thanks you,
John Miller
Author: "Michael Shipley" at Internet
Date: 04/24/2000 4:07 PM
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TO: RULE-COMMENTS at 03SEC
CC: at Internet
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Gentleman,
I agree totally with the argument with Bill Barker regarding the fair
disclosure of information by publicly traded companies to the public. 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. I have been carefully analyzing stocks
of companies I wish to invest in. I have found that on the whole information
provided by members of the SAI to be almost totally without merit. It's time
that the American investor be recognized as an intelligent member of the
capital market and not necessarily someone who needs to have his hand held
by an analyst who would classify a stock as having earnings (EPS) when the
company represented by the publicly traded shares has never in it's history
paid a dividend.
Michael E. Shipley
5320 La Cour Monique
New Orleans, Louisiana 70131
Author: stefan muszala at Internet
Date: 04/24/2000 9:19 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
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We support the proposed ruling for full and fair disclosure of coporate
information in a public forum. As individual investors this will give
us more tools to make better decisions with.
Thank you,
Stefan and Melissa Muszala
Author: "Nieder; Alvin Mr USACCSA" at Internet
Date: 04/24/2000 12:10 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs:
I urge you to adopt the proposed rule to require that companies no
longer engage in the practice of disclosing important information to Wall
Street analysts without also giving that information to the public at large
at the same time.
As an investor for more than 30 years, it has always been my view that
public companies should release public information to the public, and not
only to a select few analysts, most of whom work for large brokerage firms
(which, naturally, trade on their own accounts). Such 'limited releases'
amounts to nothing more than giving an insider's edge to the firms that
those analysts represent.
Although it could make sense to broadcast or release the information to
the general public when the corporte-analyst meeting concludes, investors
and stockholders should NOT have to seek that public inforamtion from a the
companies represented by the select few analysts, NOR have to wait for
public information until it has been filtered by hand-picked analysts.
As one example, some years ago Merrill Lynch analysts downplayed oil &
gas strikes made by Mitchell Energy & Development and held that company in
low esteem because the Mitchell brothers owned controlling stock interests.
I was 23 years old, and I got my information from the Houston Post and felt
that I could not rely on the Merrill Lynch analysts. While Merrill Lynch's
recommended stocks teetered and crumbled, I invested in Mitchell Energy &
Development and made money - before the Arab oil embargoes set in.
Respectfully,
Alvin Nieder
BAE Systems, Inc.
PO 880
Centreville, VA 20122-0880
Office Phone 703-695-7620
Author: at Internet
Date: 04/24/2000 7:43 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD_File No. S7-31-99
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I vote to let the public in. It is not in my best interest to hear analysts
interpretation of that a company says. I do have a brain in my head just
like they do.
Roger Nordstrom
Author: "Nutzman; Brian" at Internet
Date: 04/24/2000 9:34 AM
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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 may concern,
I have sent a message on this subject before, but just want to reiterate it
here. Not only is it a disgrace that Wall Street Analysts think I am too
dumb to understand what a company reports, but I also find it to be highly
unethical that a company provides info (first) to the same Wall Street firm
that may provide them equity or other services. The current system limits a
truly great marketplace and adds to the volatility and inefficiencies that
Wall Street thinks they can smooth out by their genius alone. Individual
investors are fully capable of making their own decisions and just want a
fair shot at disclosed information. Please put an end to the years of
disservice Wall Street Analysts have provided and allow individual investors
the right to equal and just access to information.
Regards,
Brian Nutzman
(Representing myself)
Author: Christian Overbey at Internet
Date: 04/24/2000 5:44 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I heartily disagree that the 'public' should be protected from
themselves. The concept of the most efficient market is debased when
information is filtered instead disseminated freely. Analysts who
follow particular industries and stocks will always be ahead of the
general public, but this should not be a codified element of a
supposedly efficient market.
--
Christian D. Overbey, AIA, Architect
Klontz and Associates
4000 Aurora Ave., N
Seattle, WA 98103
tel 206-547-4150 fax 206-547-4207
christian@lucidinvest.com
Author: "RPennise" at Internet
Date: 04/24/2000 6:44 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hi,
My name is Roy Pennise an individual investor. I'm writing to support your
proposed change in the disclosure of information by publicly traded companies.
I do not believe selective disclosure is in each investor's interest but creates
a privileged class and a not privileged class. Since I'm a member of the second
group I must let you know this now while this change is under consideration.
Thank you,
Roy Pennise
Author: timothy petry at Internet
Date: 04/24/2000 6:10 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am fully capable of doing my own securities
analysis,
making investment decisions, and living with whatever
happens.
Thank you.
Timothy J Petry
Author: "Pezzi; Rosemary" at Internet
Date: 04/24/2000 9:53 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I strongly support Proposed Regulation FD: File No. S7-31-99
Rosemary Pezzi
Author: "Barry Plemmons" at Internet
Date: 04/24/2000 9:56 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I hope you are receiving a large volume of comments on the proposed
regulation so I will keep my comments short.
I fully support S7-31-99 !
I believe every investor should be on a level playing field when it comes to
understanding the companies they choose to invest in. Giving a privileged
few the opportunity to hear information before others is similar to insider
information which gives them an unfair advantage over those not present
during the disclosure.
I sit in an office with about a hundred people, and often hear discussions
about the market and feel most of those talks provide common sense
judgements about whatever is happening.
I certainly review the opinions of the analysts. They obviously have more
time to spend on their specialty than I, and their words do not go unread. I
look at them as just another opinion, albeit an important one, but it's my
money and I make my own judgements.
Americans are not stupid people, please pass the proposal and make the game
fair.
Sincerely
Barry Plemmons
28089 Cricket Hill Rd.
Brooksville, Fl. 34602
Author: "David Price" at Internet
Date: 04/24/2000 9:22 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom It May Concern:
My name is David Price and I am writing in support of the proposed
regulation FD:File No. S7-31-99. I believe that the current practice of
disseminating information to analysts, and other entities in market
influencing positions, before allowing the general public access to the same
said information borders on criminal.
We currently have in place insider trading regulations which do not allow
employees of a company to trade their companies securities until a
reasonable time after earnings have been announced. This regulation was
enacted, I believe, to prevent sources close to knowledge from having an
unfair advantage in the market, yet the activities the Wall Street analysts
participate in seem to violate this same spirit by allowing wealthy clients
of large brokerages to get the jump on the Street and either make larger
profits or avoid losses whichever the case may be.
Sincerely,
David Price
Author: at Internet
Date: 04/24/2000 10:48 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Gentlemen,
No matter how the S.I.A. tries to spin it, the truth is that at this time
securities analysts have access to information that the public does not.
Companies share information with a favored few who then act on that
information. Whether that action is diseminating the information to their
clients, or the buying and selling of securities, the end result is the same.
The S.I.A. is acting as a gate keeper between the public and (supposedly)
public information. The public must pay the various members of the S.I.A. to
obtain access to information in a timely manner. This state of affairs is
outrageous and should be corrected immediately. The fact that this matter is
even being debated is shameful.
G. A. Rockefeller
41 Baskin Rd.
Lexington, MA
02421
Author: "Alberto Romero" at Internet
Date: 04/24/2000 12:33 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am outraged that individual investors are the "last to know" about important
financial information regarding publicly traded companies.
Selective disclosure should be fought as much as possible. I support
regulations and guidelines to reduce the "broker and institutional investors"
having the upper hand. The Internet and "cheap" mailing list technologies can
be used to terminate (or significantly) reduce such practice.
Alberto Romero
Forth Worth, TX
Author: Michael Sadewhite at Internet
Date: 04/24/2000 1:18 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99
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Anaylsts have no better perspective on the information released than I
do! Information should be released to everyone at the same time. Stop
protecting an industry!
Author: "Bill Scala" at Internet
Date: 04/24/2000 9:51 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg. FD File # S7-31-99
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Sir/Madam,
I take exception to the SIA's posisition that the investor at large is too dim
and lacks the discipline and training to use the "inside" information that is
now limited to stock analysts. This attitude would suggest hubris beyond
descripition if it wasn't so obvious that all that is at play is simple greed.
Please pay as little attention as possibe to the self-serving statements from
the SIA.
Roger Smith
Author: "Gail Shierman" at Internet
Date: 04/24/2000 7:04 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: Files no. S7-31-99
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I want full disclosure as an individual investor.
Gail Shierman
Author: "Sladic; John" at Internet
Date: 04/24/2000 8:12 AM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Publicly traded companies should be required to disclose information in a
non-discreet and non selective manner asuring that all interested
participants including individual investors have equal access to the
information. If the SEC has continued to allow and encouraged a more
"democratic" market why would you not encourage the most transparent and
free access of information critical to the investor who in the end has the
most to gain or lose.
Author: John Starke at Internet
Date: 04/24/2000 9:13 AM
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 am writing this comment on the proposed rule entitled "Selective
Disclosure and Insider Trading".
I wish to add my support for the financial disclosure legistlation.
By trade, I am a software engineer. In my line of work we have a saying,
"Many eyes make shallow bugs." Although this refers to errors in the
code writen for a program, it applies to more than just computers. The
more people that have to opportunity to look at a set of information,
the more eyes there are to point out flaws or inconsistencies in that
data. The Securities Industry Association (SIA) feels that the general
public is too stupid to handle this job, and only specially trained
analysts can be trusted with the data. I feel that anyone who wants the
data, analyst or not, should have access to it. I, for one, would rather
chart my own financial future.
Respectfully,
John Starke
--
John Starke John.Starke@ericsson.com
Ericsson, Inc. phone: +1 972 583 7047
Global Technologies R&D fax: +1 972 669 0154
Richardson, Texas ECN: 800-37047
Author: Rabbi Chaim Steinmetz at Internet
Date: 04/24/2000 8:15 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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To whom it may concern:
I know 1984 has come and gone, so an it really be true the SEC believes
we all need a big brother? the time has come for all investors to have a
level playing field; let analysts earn their money through analysis, not
inside information.
Sincerely,
Chaim Steinmetz
Author: at Internet
Date: 04/24/2000 9:50 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs,
We are individual investors and feel it necessary to support the proposed
regulation. As a participant in the capital markets, we require and need as
much unfiltered information as is available. The current practice of small
group of priviledged and selected analysts getting prefered access to selected
information prior to the rest of the market bothers me to no ends. We prefer to
draw our own conclusions and don't need or want the 'filter' currently being
place on this flow of information. If the markets are to be truly efficient,
then this proposed regulation will start us down the right path.
Sincerely yours,
Win Stevens
Anne Stevens
205 Barberry Drive
Wilmington, DE 19808
Author: "Swiderski; Peter" at Internet
Date: 04/24/2000 10:10 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Subject: Proposed Regulation FD: File No. S7-31-99
Sirs;
I am not writing on behalf of the securities firm for which I work, and in
truth, probably speak at odds with any potential positions held by
management here or the SIA. I speak as a private individual and investor in
equity markets.
I agree with your position on this rule and feel you must resist industry
pressure
to change it. I feel strongly - and so does everyone I have spoken to - that
information
made public by a firm should be made public to everyone and not just
analysts of investment firms. The official position of the SIA speaks for
the investment industry but not for individual investors and reflects a
selfish and narrow bias.
It is increasingly clear that the private investor community is both better
educated and sophisticated than ever before and a significantly large
component of the individual investor community can understand and integrate
this information without the required intermediation of the analyst
community. Furthermore, it is ever more clear that the analyst community
serves an increasingly irrelevant role in accurately assessing and updating
the public on a firm's financial condition, judging by the huge numbers of
BUY or STRONG BUY recommendations out there. Analysts no longer seem able
to review information and provide meaningful guidance so the individual
investor should be allowed equal access to that information. Why are
customers of the old-line huge investment firms allowed early access to this
information? What is so fair about that?
Ironically, the users of the internet or discount brokerage firms are most
likely to be the ones who are sophisticated enough to make their own
decisions. Yet, we operate at a disadvantage to the old-guard investors who
get first dibs on information. We can filter our own information, thank you
very much, and we won't automatically be assigning a STRONG BUY to every
stock out there. It is only fair that ALL investors have equal access to
this information, and EQUAL means TIMELY.
Please, consider that my voice is not an isolated one and that we are all
adults capable of constructive thought. We shouldn't be discriminated
against because we are unwilling to pay an old-guard brokerage firm $500 in
commissions on a trade. Where is the justice in that?
_________________________________________
Peter Swiderski
Vice President, Product Development
BHF Securities Corporation
590 Madison Avenue
New York, NY 10022-2540
Tel - 212-756-2737
Fax - 212-756-2841
Email - pswiderski@bhfsc.com
Author: "Szymanski; David" at Internet
Date: 04/24/2000 8:07 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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All:
I don't understand why I am deemed to ignorant to understand the
disclosures from publicly traded companies. Why I must I wait and be fed
selected bits of information rather than immediate full disclosure? I do
understand the analysts unwillingness to level the playing field; it is not
in their best interest. However, I am the investor in this case.
If you can find me the analysts, who consistently, accurately
predict the market or even the success of every company they report on, then
I will retract these comments. Allow me to make the same mistakes and have
the same successes as they do. This is all we ask.
Dave
Phone: (281) 518-8941
Email: david.szymanski@compaq.com
Author: Alan Tigert at Internet
Date: 04/24/2000 8:40 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I would like to have access to any data that could effect my trading
decisions.
Author: Ashmore Todd at Internet
Date: 04/24/2000 9:58 AM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am responding to the current issue of proposed regulation FD. If the
"markets" are truly free markets then ALL investors get the SAME information
at the SAME time. I support Regulation FD as I am my own analyst and do not
need people (who apparently feel that they are smarter than the average
American) getting better information, faster than the small investor. For
them to claim that they serve a purpose for me is ridiculous. These Wall
Street "power analysts" do not have the same investment horizon, risk
profile or general opinion that I do, so how do they serve any purpose for
me.
Level the playing field.....approve Regulation FD.
Author: at Internet
Date: 04/24/2000 8:49 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I feel very strongly, that as an individual I am fully capable of analyzing
raw information from publicly traded companies. There is no rational
argument as to why information must be filtered before it reaches me, other
than I am not smart enough to handle it. I do not believe I need Wall
Street analysts to protect me from myself. I support full disclosure of all
information by publicly traded companies to the entire public. If someone
wants to pay analysts a premium for their ability to interpret that data, so
be it. Just make sure they don't get information that I can not get!
Thank you.
Brian Trueblood
Partner
Lucas Group
800-878-4666, ext. 131
Author: "Joe Wright" at Internet
Date: 04/24/2000 9:08 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
1) Is it true that "it hardly needs saying that analysts perform a necessary and
valuable function in the U.S. capital markets"? Is it true that to perform that
necessary and valuable function they need better information than the
participants in the market?
HIGHLY UNLIKELY
NO
2) Is it true 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"?
NO
3) Is it true that analysts make the markets less volatile?
ONE MILLION TIMES NO!
4) Is it true that analysts spend much of their time ferreting out negative
information about companies
HIGHLY UNLIKELY
Another attempt to control the markets for the exclusive good of insiders and
'market whores'. It's our freaking money and we want the same access to
information as the 'analysts' .
Joe Wright
http://www.sec.gov/rules/0424b01.htm
