Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Adams Family" at Internet
Date: 04/24/2000 5:14 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 a level playing field and think it is unfair and undemocratic that a
certain few privileged insiders on the stock exchanges are allowed to obtain
information and then act on it before the news is released to the general
public. Please excuse the runon sentence...John Adams, MD
Author: at Internet
Date: 04/24/2000 5:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Company information should not be made available to a select group of
"insiders" AKA analysts prior to general dissemination. This violates the
very core of American values and certainly damages America's reputation for
financial transparency -- something we insist the rest of world emulate.
Marilyn Baker
d8abaker@aol.com
Miami Beach, FL
Author: "brbarnett" at Internet
Date: 04/24/2000 1:04 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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This needs to be adopted. It is ridiculous to think investors must have someone
ferret out or decimate information for them. Lets eliminate the good ole boy
network and level the field.
Bruce Barnett
Author: at Internet
Date: 04/24/2000 5:23 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: No. S7-31-99
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I am an individual invester with twenty-five years experience in doing my own
investment analysis. I fully support the SEC position in this matter. I
oppose the positon of the SIA, and consider it an insult to my intelligence!
John Barton
Author: "Arthur J. Bozogian" at Internet
Date: 04/24/2000 6:18 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation: File No. S7-31-99
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I believe everyone has a right to receive company information at the
same time. It is unfair to give information to institutions first.
This allows time for them to make informed buy or sell decisions
before the general public.
Thank you,
Arthur Bozogian
Individual Investor
Author: Jim Butcher at Internet
Date: 04/24/2000 5:05 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 am somewhat offended by the comments of the
Securities Industry Association (SIA) representatives from April 6, 2000, in
particular the following:
"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."
and
"they can give the markets rapid guidance as to the significance of new
information, thereby mitigating individual knee-jerk reactions to specific
information."
Apparently the SIA feels that individual investors like myself lack sufficient
wherewithal to fully appreciate the complexities of a prospectus or a
financial statment. However, I have found no such difficulty in reviewing
these documents, nor in making informed decisions based on the information
they contain. I much prefer the opportunity to process the information as I
see fit, instead of having
it first filtered by another organization with an agenda which may be entirely
out of sync with MY real world investment objectives. It seems obvious to me
the SIA's real agenda in this matter is to preserve there current advantage of
receiving information in advance of the general investor population, allowing
them to "leak" this information to preferred clients and collect commission
fees for the resulting transactions while benefiting these preferred clients
who can make buy or sell decisions before the news has time to impact the
overall market.
In short, I feel the SIA is in no way interested in passing information on to
the general markets as a altruistic gesture to help the investing public. They
are interested in hoarding as much information as possible, only to release it
at the time which most benefits themselves and their clients.
I suggest the Proposed Regulation FD be enacted as quickly as possible, so
that the members of the SIA can compete for business based on the quality of
their work, not some competitive advantage afforded them by an outmoded system
of information dissemination.
Jim Butcher
ckcjimb@netscape.net
Author: Justin Cook at Internet
Date: 04/24/2000 2:13 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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LEVEL THE PLAYING FIELD!!!
Sincerely,
Justin Cook
Author: "DANIEL CURTIS" at Internet
Date: 04/22/2000 9:14 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 investor, I feel that there is no purpose served to allow analysts to have
access to information before the general market. I think the current
"arrangement" leaves the individual investor with a bitter taste and gives the
trial lawyers a foot in the door for class action litigation. Please allow
information to pass freely in the business world and require full immediate
disclosure of news to the public. LEVEL THE PLAYING FIELD!!!
Sincerely,
Daniel P. Curtis
Johns Hopkins University
Author: "Chris Ellis" at Internet
Date: 04/24/2000 5:46 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.
PLEASE RECORD THE FACT THAT I STRONGLY OPPOSE ANY WATERING DOWN OF THE
PROPOSAL TO REDUCE THE SELECTIVE DISSEMINATION OF INFORMATION WHICH IS SO
PERVASIVE IN THE MARKETPLACE TODAY. THIS HAS CAUSED AND CONTINUES TO CAUSE
GROTESQUE ADVANTAGES FOR INSIDERS, THEIR FIRMS AND THEIR CLIENTS, WHEN WE
ALL KNOW THAT THE RULES FOR ENTRY ARE COLLUSION WITH THE COMPANY CONCERNED.
Christopher Ellis
Author: Peter W Erdmann at Internet
Date: 04/24/2000 2:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I invest my own money based on my own decisions, the analysts that I
have had the good fortune or bad as the case may be when I did use a
major brokers before taking up my own trading decisions where always
recommending stocks that were over priced, over the 200 day moving
average and in most cases it seems just helping large investors get rid
of inventory at inflated prices. One recent stock to look at is SGNT
were brokers recommended it at inflated prices, then after many bought
feeling good, they downgraded it for massive
losses for individual investors. I think people that care about their
money should see the information up front, not filtered into the pockets
of unscrupulous anilylists. I ask you to look at the recommended list
from a few weeks back and realize that almost everyone who relies on
analysts are out of pocket. I think we have the right to have the same
information to protect our money from what is a old boys network of pure
manipulation by the larger brokers. It is only fair and the only why to
run a free market. I hope you don't give in to the special interests and
remember this is only right and good that we all share the same
information. This is supposed to be a free market in a free country and
you don't need to hang beanbags of unfair rules around the small
investors. Many will still use the system in place and the few that
husband their own money need to have a fair playing field.
Peter Erdmann
Seattle WA
Author: "Dwan Forester" 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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Dear Folks,
Please level the playing field. To say that I am not smart enough to understand
what is going on with management in public companies is like saying I don't know
how to handle my own checkbook.
Just because some so-called experts need the hedge to make more dollars for
their clientel should not keep me from the same information. These experts would
say that I cause volatility in the market----WRONG! They by their insider
information could cause the market to drop or raise but to their clients'
advantage.
Please help the little folks out and allow us the same information.
Thankyou.
Sincerely,
Dwan Forester (a small but interested investor)
122 Mohawk Street
Morristown TN 37813
Author: Tony Gomez at Internet
Date: 04/24/2000 4:49 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As a shareholder, I am a part owner of public companies. I would like
simultaneous access to the information provided by my companies to other
investors and analysts. I make my own investing decisions, so selective
(rather than truly public) disclosure of information to investment analysts
places me at a temporal disadvantage, because I am not guaranteed an equal
opportunity to digest information and react to it.
Thank you for your consideration,
Tony Gomez
Professional Education International
Author: Anuj Gupta at Internet
Date: 04/24/2000 5:19 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Strongly in Support of Proposed Regulation FD: File No. S7-3
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To the SEC:
I wish to strongly support efforts of the Chairman of the commission
to eliminate selective disclosure of material information. As a
stockholder
in various companies, I see little reason why other stockholders should
receive information in a company I own before I do. Please pass
this important regulation designed to help the American markets operate
freely and fairly.
Thank you,
Anuj Gupta
Author: "Bryon T Hibbetts" at Internet
Date: 04/24/2000 1:55 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Full Disclosure to Public
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I am an individual with IRA accounts where I purchase and sell stocks without
the aid or advice of anything other than the public media.
That there are people who have access to information that I do not have, and
these people are able to trade on this information, means that the SEC
sanctions insider trading.
Unfortunately, the people who have this access are the industry analysts. As
such, they have the financial clout to single handedly move a stock's price
based upon their findings. As an individual, I will not find out about this
information until well after the industry giants have corrected the stock
price.
I willingly take the risks associated with owning stocks. It galls me that
part of that risk is that the inside analysts have and use their inside access
to move markets before I have a chance to mitigate those risks.
Please keep the individual's rights foremost in the upcoming debates on
insider disclosure to the industry analysts. The large fund and brokerage
companies rightfully have many advantageous in the stock market. They do not
need the unfair advantage of advanced information as well.
Thank you.
Bryon Hibbetts
Author: "HOYTE;DEREK(HP-Vancouver;ex1)" at Internet
Date: 04/24/2000 11:37 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,
In a free country and in the information age that we live, it is unconscionable
to restrict the public's access to information, especially financial information
about companies they own.
Respectfully Yours,
Derek Hoyte
Hewlett Packard, Co.
Author: "Huffman; Nelson" at Internet
Date: 04/24/2000 4:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Selective Disclosure
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...Selective Disclosure.
The SEC has proposed a regulation that would force companies to stop giving
inside information to analysts ahead of us, the individual investors. It is
one more step toward leveling the playing field and putting the Wise in
their place. We have until Friday to make our opinion heard.
I believe that the practice of insider information to analyst prior to the
individual investor should be stopped!
Author: at Internet
Date: 04/24/2000 5:13 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:S7-31-99
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Ladies and Gentlemen:
Concerning the subject regulation, it is my thought that the entire Wall
Street scene with its thousands of Brokers, Investment Bankers, and Analysts
is an insider information system, that manages and manipulates important
information to the public, and others not inside, for its own enrichment, and
the safety of its own houses and major investors. The public, left out of the
knowledge, and future news, is unable to protect its investments, until well
after these interests have tipped, traded and poised themselves to be in
great shape, after they have positioned to take a downturn that they have a
hand in causing, or to "hype" a stock investment that they will fully benefit
from. The private investor has no hope of being able to preserve his capital,
or act on this knowledge, until it is far to late. He becomes the goat, and
the loser. Wall Street becomes the winner, along with the big houses, and
their most valuable larger investors. If the existing system reduces
volatility, then what do we call the extremes we have been experiencing. In
this last severe slide, selling by the big institutions and major investors,
not principally the public occurred, and brought the market crashing down
where it now flounders. They all got out early and left the crumbs for the
small guys. The brokers and advisors all advised to stay with it or buy as
the prices receded The system is not defensible on the basis that they are
helping the individual investor, or smaller investors in any reasonable way.
That is a general consensus of those to whom I speak. I join in their belief.
The insider information needs to be against the rules. This information needs
to be shared with everyone, without regard to his business or investment
interests. Please consider getting legislation passed to put this behind us.
What is going on including the formation of the Internet bubble is totally
the responsibility of what governance of the market is allowing the insiders
to do to enrich themselves and protect themselves, with the public be damned.
Sincerely, James B. Johnson, AIA, Architect, Retired
Author: Mike Johnson at Internet
Date: 04/24/2000 6:04 PM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I would like to express my strong support for the "level playing field"
suggested by the above listed regulation.
The equity markets are, I believe, for everyone. As a beginning investor, I
have been very pleased to learn that the old barriers to entry into
ownership of stocks are slowly falling. The fact that I can access
quarterly and annual SEC filing simply by clicking my mouse to the correct
Web page is, to me terrific.
However, I'm disappointed that supposedly "public" companies are "private"
about important financial information that I, as an independent investor, am
not privy to. When the only way to become an investor was deal with a Wall
Street broker, this sort of information channel may have been useful. Now
that there are discount brokers, DRIPS, ESPPs, and other ways to become a
stockholder, I don't see why there needs to be a monopoly on some of the most
important financial information needed to be a smart investor. I realize
that Wall Street feels that its monopoly is threatened. I counter with the
statement that a public company which considers some of its public info
"private" is not really following the rules and regulations that public
companies are supposed to follow. Please pass the level playing field
regulation.
Author: Dean Krouse at Internet
Date: 04/24/2000 5:23 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I think it is extremely important for the individual investor to have the
same access to corporate information as the large investment houses. I
don't think anyone is opposed to the investment houses having this
information but I feel strongly that it should be made available to ALL
investors at the same time.
I don't see how anyone can claim that there is a level playing field unless
ALL investors have equal access to corporate information.
Author: "Faye Lakeman" at Internet
Date: 04/24/2000 5:20 PM
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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
To the SEC re Proposed Regulation FD: File No. S7-31-99:
I am an individual investor who takes complete responsibility for all of my
investment decisions. Availability of timely, complete and comprehensive
information regarding publicly traded companies is as essential to my financial
well-being as that of any professional broker or analyst or other "insider".
I heartily endorse Proposed Regulation FD: File No. S7-31-99.
Thank you for your time. "Down with selective disclosure!"
Sincerely,
Faye Lakeman
22 Beacon Lane
Cape Elizabeth, ME 04107
(207)767-7286
Author: Eric Lotze at Internet
Date: 04/24/2000 2:23 PM
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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 register my support of the above regulation change.
Thank you,
Eric Lotze
4372 W. Pt. Loma Blvd. #D
San Diego, CA 92107
Author: Wanda Lucas at Internet
Date: 04/24/2000 4:48 PM
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TO: RULE-COMMENTS at 03SEC
TO: Wanda Lucas at Internet
Subject: RE: Comments on Proposed Rule:Selective Disclosure and Insid
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> -----Original Message-----
> From: Wanda Lucas
> Sent: Monday, April 24, 2000 4:22 PM
> To: rule-comments@sec.gov
> Cc: Wanda Lucas
> Subject: Comments on Proposed Rule:Selective Disclosure and Insider
Trading
>
> I have been an independent investor for 3 years. I believe analysts
underestimate the number of investors who are willing to perform due diligence
in order to select stocks. We should at least be afforded the same information
as independent analysts. I support this rule.
Author: Dana Lundy at Internet
Date: 04/24/2000 3:12 PM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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It is with much concern that I write this to impress upon you the need for a
'level playing field' so to speak with regard to open and public disclosure
of company and related information. I manage only one portfolio - mine -
however, I depend heavily upon information available through my research
efforts. And although mine is not a huge portfolio (approximately $750,000)
it is imperative that I have access to timely and informative data. I am
simply a typical 'John Q. Public' individual out here that encourages you to
ensure that fair disclosure of information is available to all.
Thank you,
Dana Lundy
dana.lundy@wonderware.com
Author: "Frank Machado" at Internet
Date: 04/24/2000 6:00 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:FileNo. S7-31-99
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I support the above Regulation and urge that it be passed.
Frank
W. Machado
Author: "Kevin Marshall" at Internet
Date: 04/24/2000 5:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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My Name is Kevin Marshall. The Motley Fool website was good enough to give
me your email address.
I am fully in support of the Full Disclosure Regulation. Selective
disclosure is unfair, and provides large financial firms the ability to move
on information before the general populace. These firms build their
reputation on the idea that they are better, and can do more, than the
average investor... well, its easy to be better when you have access to
resources that your competition does not. Open up the information to
everyone, and let capitalism thrive the way it was meant.
Thank you,
Kevin Marshall
Author: Mike McCown at Internet
Date: 04/24/2000 5:03 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. I am at least as
intelligent as the vast majority of analysts. I have found that when I
make my own decisions, I do better than when I rely on analysts.
My goals are designed to improve *my* financial situation; Analysts'
goals are designed to improve *their* financial situation. I am quite
happy for others to rely on analysts, but I do not rely on them. I
should have access to the same information they do and make my own
decisions.
Gary Mason
2502 Iron Forge Rd
Herndon, VA 20171
garybmason@bigfoot.com
Author: "Maurer; Julie (JL)" at Internet
Date: 04/24/2000 4:13 PM
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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 writing in regards to the proposed regulation which would require public
companies to disclose information to the public, rather than to a group of
analysts of their choosing. Yes, I read about this issue at the Motley Fool
internet site, and I understand that you have received many comments from others
who learned about the issue there. I understand that the argument against this
proposed regulation stress that the majority of individual investors are: 1) not
interested in the information and 2) can't understand it without an analyst's
help. These arguments miss the point. The point is, if there are SOME
individual investors who have the interest, background, and ability to
understand that information, they deserve a level playing field. The
"interested minority" should not be punished simply because they're a minority!
In this day of electronic communication, there is no excuse for not allowing the
entire investment community real-time access to important financia!
l information about public compa
nies.
Best Regards,
Julie Maurer
Author: "Ken McCook" at Internet
Date: 04/24/2000 5:58 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Stop Selective Disclosure
Ken McCook
Author: at Internet
Date: 04/24/2000 6:07 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Comment on Proposed Regulation FD: File No. S7-31-99: It is only fair that
news should be released to all interested parties simultaneously. To allow
companies to work with trading firms, market makers, etc., by giving them
advance notice of news -- good or bad -- creates an unfair market where
certain organizations have a large advantage over others. Through the
internet and business television channels, it is possible, and expected, to
receive timely information. There is absolutely no reason, short of unfair
business practices, that brokerage firms/market makers should have access to
this news before the public. This practice should have been discontinued
long ago, in a market where everyone has instant access to news through the
internet. It should be criminal to withold pertinent information from the
public and individual stockholders and investors, while allowing others the
right to benefit from the news before it is made public.
If the SEC does not stop this practice, they should at least require all
companies, market makers and brokerage firms to disclose up front, in clear,
concise terms, that this practice exists and that the public is basically at
the mercy of these companies and the brokerage firms/market makers that have
access to the information. This disclosure should be made before each and
every trade is executed to make sure the public is aware of this unfair
business practice.
Thank you for allowing me to voice this comment.
Lynn McGeein
1600 Mallard Lane
Virginia Beach, VA 23455
Author: "Jason Miller" at Internet
Date: 04/24/2000 4:18 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD: File No. s7-31-99
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I strongly support individual investors receiving corporate information at
the same time as Wall Street analysts, therefore, leveling the playing
field. If the analysts provide such a necessary function, and are so
critical to the workings of the securties exchanges, I do not understand why
they are insecure about sharing information with individual investors. I
think giving critical investing information only to a privelaged few (the
analysts), who in turn serve a privelaged minority of Americans wealthy
enough to have a broker, encourages a widening of the gap between rich and
poor. I think that flies in the face of the entrepreneurial spirit upon
which our economy is based. One of the analysts' arguemnents is that it is
unrealistic that individuals will study and research stocks on their own. I
am one who does. If others want to pay someone else (and trust someone
else) to do their homework for them, fine, but don't prevent me from
obtaining the information I need to do my own research. I wanted to express
my opinion on this matter.
Thank you
Jason Miller
Author: "Richard A. Paquette" at Internet
Date: 04/24/2000 5:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I wish to go on record regarding the Proposed Regulation FD: File No.
S7-31-99.
I want all people who are interested in a company to have the same access to
information at the same time.
Richard Paquette
11 Saint John Street #A6
North Haven, CT 06473
Author: "Christopher C Parrish" at Internet
Date: 04/24/2000 4:36 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 or Madam,
As an Individual Investor, I think that we should have the same access
to information as the larger investment houses have.
Sincerely,
Christopher C Parrish
Author: "Perrin; Roger (rp)"
Author: at Internet
Date: 04/24/2000 4:33 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
When will the SEC put an end to the collusion between brokerages and companies
at the expense of average American traders/investors?
Once again I see the impact of brokerages trading on inside information, this
time with the NASDAQ stock NZRO. Last Wednesday/Thursday, in the absence of
any news announcement by the company, the stock increased 85+% in price on high
volume. Today, the rest of the investing public learns that QCOM has
purchased 10% of the company--a fact clearly disclosed to brokerages/analysts
last Wednesday, well ahead of today's public announcement. The
result--brokerages using the strength created by today's NZRO announcement
and dumping as many shares into retail investors' hands today as possible (using
INCA as their primary dumping vehicle).
Ironically, had an employee of NZRO told me last Wednesday about the QCOM deal,
and I purchased a substantial block of shares, I could be in violation
of SEC regulations, correct? Why the double standard when it comes to
brokerages. This is a crime.
When will the SEC do something about leveling the playing field for all
traders/investors, especially given that individual investors now own nearly
50% of all stocks (not including positions in mutual funds held by individuals?
Take some action on behalf of the "average American investor" for a change.
Dennis Pope
Chicago
Author: Allan Pratt at Internet
Date: 04/24/2000 3:20 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As an individual investor, I strongly support the changes proposed in
these regulations. There is no legitimate reason why any group of
investors or commentators should have special access to corporate
information before any other group.
Allan D Pratt
Tempe, AZ
Author: at Internet
Date: 04/24/2000 4:37 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am very much in favor of giving everyone a fair break in learning about
what is going on in the market. I represent an investment club of 15
members and a family investment club of 8 members. I am also an active
participant in the market. By active, I do not mean a day trader, but a
long term investor. The level of sophistication by people I talk with
daily is growing rapidly and should not be hindered by selective
disclosure to analysts who can sway the market by dropping a pin.
JoAnn Qandil
A-Z Enterprises
Lawrence, Kansas
785-841-6254
Author: Simon Ramseier at Internet
Date: 04/24/2000 11:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As an individual investor, I strongly support any regulation against
selective disclosure. In my opinion, a market is a truly free market only
if all participants have access to the same information.
The SIA claims that "analysts perform a necessary and valuable function in
the U.S. capital markets". I disagree. But even if this were correct, do
they really need better information than the participants of said markets
in order to perform this function? I believe the real reason for the SIA's
standpoint is the money that can be made by knowing more than other market
participants. However, a market where not all participants are treated
equally is not a fair and free market.
The SIA claims that "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". Not everybody
wants to get to know the companies they invest in. However, those who want
to do this should be allowed to do so. The SIA wants their members to be
the only ones with access to the full information. I ask for full
information for everybody.
Is it true that analysts make the markets less volatile? Such a claim (as
made by the SIA) must be backed up by data.
Is it true that analysts spend much of their time ferreting out negative
information about companies? Personally, I haven't seen many "Sell" ratings
lately.
Analysts (as represented by the SIA) want access to information nobody else
has, because it gives them a financial advantage over individual investors.
As an individual investor, I am opposed to selective disclosure and in favor
of regulation against it because in order to have a free market, everybody
must have access to the same information at the same time.
Regards,
Simon Ramseier
Zurich, Switzerland
Author: "Larry Sanders" at Internet
Date: 04/24/2000 3:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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Change the damned thing. it's really stupid and is going to be changed one
way or another.
Larry Sanders
Author: "Mary Ellen Scott" at Internet
Date: 04/24/2000 6:20 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Selective Disclosure
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I feel that the average investor has the same rights to information that the
analysts get. I have seen so much spin from analysts that I prefer to do my own
due diligence. After all, I'm spending my money. The average investor deserves a
level playing field. Before Abby Cohen spoke a few weeks ago I can't believe she
hadn't already sold her tech stocks. I also can't believe that Mark Vervetta
from Baron's doesn't short all the internet stocks he's been writing about
either. IMHO! By the time the average investor knows anything the party is
already over. How fair is that? Thanks for listening.
Mary Scott
248 478 2173
Author: "Robert Semb" at Internet
Date: 04/24/2000 3:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Let us have fair disclosure.
Robert Semb, P O Box 104882, Jefferson City, MO 65110
--
Bob Semb resemb@mail.ultraweb.net
573-636-5332
Author: "Chandra Shah" at Internet
Date: 04/24/2000 4:15 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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It's a pretty commonsense rule in my opinion, one that many investors might
logically assume must already be the law of the land, but unfortunately isn't.
I strongly support the proposed rule.
-Sincerely
Chandra Shah
chanshah@intrex.net
Author: "Penny Simms" at Internet
Date: 04/24/2000 5:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No.S7-31-99
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This creates a very unlevel playing field and does not seem in the
best interest of free enterprise. How can you assume that an
individual cannot process information and make financial decisions
in their own best interests at least as well as paid brokers out to
earn a commission on sales?!?
Margaret Simms
Atlanta, GA 30033
Author: "Keith Stacy" at Internet
Date: 04/24/2000 5:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am sending my input for the above proposed regulation. I am in favor of
no longer allowing important information to be given to Wall Street analysts
before it is made available for the general public. Allowing this to happen
only encourages corruption.
Keith Stacy
kstacy@erols.com
Author: "Streb; John F" at Internet
Date: 04/24/2000 4:15 PM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I believe the change in rules under this proposal to be good for the
individual investor (me, for example) and the market at large. The current
rules seem an unfair advantage to the analysts and brokers of Wall Street.
I understand why they so urgently want to protect their position.
I believe it's time that decisions about the rules are made in the interest
of fairness and objectivity and not due to Wall Street lobbyist attempts to
frighten the SEC with dooms day stories if the new rule is passed. The SEC
needs to remain unemotional when making this decision.
Thank you.
John F. Streb
Embedded Software Engineer
The Boeing Company
john.f.streb@boeing.com
314-234-8168
Author: at Internet
Date: 04/24/2000 4:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As private investors, we are in favor of the proposed Regulation FD.
Free and unencumbered information allows the investor to learn of
opportunities and decide their impact much quicker. Of course, not every
investor will understand the information they receive, and are free to
continue relying on their analyst....OR, at least have a candid discussion
with other investors who also received the identical information....
Ironically, at least one of the reasons we support this regulation is cited
in the SIA filing, in which the competitive spirit of the analysts is
described. Their concern that analysts' withhold questions that could tip
off their competitors smacks of the very reason information shoulded be
shared universally and simultaneously: In our opinion, the competitive
spirit of analysts undoubtedly leads to dis-information being spun in the
presence of other analysts, in order to protect their respective "correct"
spins. (This is no surprise, save that the SIA cites this as a reason to
continue filtering information to investors.) Having information first
filtered in this atmosphere simply means that true information is a matter of
roulette: Sometimes you get it, most often you don't. It all depends on
your analyst, and the questions asked / not asked while they were present.
We do believe analysts serve, and will continue to serve a purpose -- but
they will be more accountable when the public can question and/or validate
their spins. It's not only fair to share the information at the same time,
it's an opportunity to high-grade analysts.
Leland E. Tate, private investor
Nina P. Tate, private investor
Author: at Internet
Date: 04/24/2000 4:30 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed Regulation FD
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Dear Sirs;
It is about time that the selective disclosure of company information to
"select" entities was stopped. Analysts have been in bed too long with the
companies they cover.
I wholly agree with your proposed Regulation FD and I SUPPORT it.
While you are at it, why don't you require INSIDER SALES to be made public
BEFORE the fact?
Regards... Gene Uneberg (631)361-2017
Author: James Unterburger at Internet
Date: 04/24/2000 2:52 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 am writing to express my support for the proposed
Fair Disclosure rule. It seems patently unfair
to me, a shareholder or potential shareholder, for
others to receive material information on a preferential
basis. I also believe the Securities Industry Association's
comments to this matter to be disingenous and patronizing.
It is quite irrelevant whether or not anyone is intelligent
enough to "understand" the information after all. (Most of
us are able to make an intelligent interpretation of the
information, but being able to do so should not be a prerequisite
to receiving it.)
In a free market, individual interpretation and, yes, emotion,
are part of the equation of how to value some commodity or
share of stock.
Therefore, it behooves us all to ensure that information
and discussion be available equally to us all.
Sincerely,
James Unterburger
Portland, OR
jamesu@europa.com
503-788-2845
Author: at Internet
Date: 04/24/2000 5:29 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 or Madam:
I have been an investor in stocks and mutual funds for the past 10 years and
like many individual investors, I believe that companies that are traded
publically should reveal important information publically. Selective
disclosure is a damaging practice that hurts the individual investors.
Transparency and free public access to important company information is
essential in the free market system. I strongly urge you to eliminate the
current system of selective disclosure. What individual investors need is
MORE access to critical company information!
Thank you for this opportunity to have my voice heard.
Mark Vajaranant
Chicago, Illinois
Author: at Internet
Date: 04/24/2000 5:40 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 in support of full disclosure by companies to both the analyst and the
public at large.
Diana Wang
Author: at Internet
Date: 04/24/2000 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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Gentlemen:
I would like to encourage you to move in the direction of ensuring that the
public receives any investment information at the same time that it is
provided to the "professional investment community".
Thank you,
Charles A. Wethington, Individual Investor
http://www.sec.gov/rules/0424b02.htm