Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Larry Adamczyk at Internet
Date: 04/24/2000 6:57 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Jonathan G. Katz, Secretary,
Securities and Exchange Commission,
450 Fifth Street, N.W., Stop 6-9,
Washington, D.C. 20549.
Re: Proposed Regulation FD - File No. S7-31-99
Dear Mr. Katz:
I write in support of proposed regulation "FD." The degree to
which individual investors impact, and in our aggregate constitute, the
market, has and will continue to increase as more people take control of
their investments in individual stocks and varied retirement plans. In
this regard we do not act on the advice or counsel of "analysts." We are
performing analyses on our own behalf, and for this we require access to
the raw information of commerce. In order to participate on a level
playing field we require, and deserve, access to the same
information at the same time as other market participants.
The spectre of this level playing field terrifies and threatens
the livelihood of for-hire analysts.
I also wish to respond to the comments submitted by/on behalf of
the SIA in a
communication dated 6 APR 2000.
The SIA writes:
"We also think that the term "selective disclosure", which the
Commission uses in the
proposing release, is overly broad. Disclosure that is made
"selectively" to a favored
analyst in order to obtain an improper quid pro quo is
unquestionably problematic.
However, the proposal targets ordinary channels of communication
between an issuer
and analysts that do not involve nefarious motives. As we discuss
more extensively
below, we believe that these communications help get information
into the marketplace,
whereas the proposal will discourage issuers from exchanging ideas
or information with
analysts, as well as deter analysts from vigorously competing to
glean useful information
for their clients and the markets."
This logic has several flaws:
"Selective" disclosure is, by its nature, "problematic." Timely
access to information is at
the heart of meaningful participation in the market. What price
would a for-hire analyst
pay to have access to market information three minutes, three
hours, or three days
ahead of his competitors? What would she pay to continue to have
such an advantage?
If one is the sole conduit of certain (non-mandated for release)
information then one will disseminate it as a work product, for pay, and
on a schedule and in a forum that suits
one's own needs, not those of other market participants.
SIA continues:
"The proposal could result in issuers declining to engage in
dialogues with individual
analysts or small groups of analysts and instead insisting on
sessions at regular intervals
open to a number of analysts, with listen-only access to the media
and the public. These are likely to take on the orchestrated character
of a Presidential news conference in which members of the audience are
authorized to ask one question, and perhaps a short follow-up question,
but not a series of questions in dogged pursuit of the facts.
Undoubtedly, the questions from the different participants will
not be coordinated or
follow in any logical order or comprehensive way. Due to fierce
competition among
analysts to obtain the best information, they will be
reluctant to ask questions in an open session that tip off their
competitors as to the
direction of their thinking or information that they think would
be meaningful. If the
questions cannot be asked in private, they may not be asked at
all. Is that good for the
market?"
This reasoning is also specious.
It appears that members of the SIA have not observed any
competition between
journalists serially hounding newsmakers during a news conference
or performing
exhaustive individual research to bring together the pieces of a
complicated story.
If competing for-hire analysts hesitate to ask the tough
questions, individuals with their
own funds at stake will certainly not be so bashful. The SIA on
the one hand says that
Companies will hesitate to divulge information into a free market.
On the other hand,
they produce convincing figures that show that companies are
already making
conference calls public in real-time. The real question the
for-hire analyts seem to be
asking is, "Can the SEC help us try to put the jini back in the
bottle?"
Sir, I strongly encourage you to resist the efforts of entrenched
interests to hold back the forces of progress which have helped make the
boom of the last decade possible.
Sincerely,
Larry Adamczyk
Author: "Almeida; Joe (LAX)" at Internet
Date: 04/24/2000 4:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The proposed rule is outstanding. Please do what you can to make this a law.
It is a fair, common-sense law. And needs to be implemented as investing for
future retirement becomes a part of more and more people's lives.
Thanks for listening.
Joseph Almeida
Desktop Support
Initiative Media North America
818.728.2502
Author: "dkbecker" at Internet
Date: 04/24/2000 7:48 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen:
I believe that my interests as an individual investor would be furthered as
a result of the proposed rule. I do not find that the generality of
"analysts" provide any benefit to me, or the market; rather, by access to
privileged information, they provide only a benefit to themselves and their
companies.
Sincerely,
Donald B. Becker
Author: "George Bingham" at Internet
Date: 04/24/2000 4:43 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The current system of selective disclosure of corporate information enjoyed by
the brokerage industry is basically and intrinsically unfair. The individual
investor deserves to receive the same information at the time of disclosure in
order to make informed investment decisions independently of an analyst's self
serving "interpretation" of the data. The average investor today is certainly as
intelligent as most of the analysts and brokers one encounters in the investment
community and deserves to be on equal footing with the brokerage industry.
The assertion that "analysts perform a necessary and valuable function in the
U.S. capital markets" is certainly subject to considerable debate.
Author: Damon Boyle at Internet
Date: 04/24/2000 5:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
We need to have the stock markets fair to everyone. Please stop selective
disclosure, it's just not fair.
Damon Boyle
Author: at Internet
Date: 04/24/2000 8:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The SEC should NOT favor Wall St. analysts with early release of information.
It should be simultaneously released to ALL. Thank you.
James E. Brooker
47 River View Dr.
Essex Junction, Vt. 05452
802-879-6267
Author: "Bob Byrum" at Internet
Date: 04/24/2000 7:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation: File No. S7-31-99
------------------------------- Message Contents
In fairness to everyone, selective disclosure should not be permitted. I am in
full agreement with Commissioner Levitt's proposal. .....Robert W. Byrum
Author: "Gerry Chike" at Internet
Date: 04/24/2000 6:31 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: gerry@netzeit.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To whom it may concern:
Please stop Proposed Regulation FD: File No. S7-31-99. This proposed regulation
is favortism at best i.e. the proposal clearly favors a few (very well heeled)
Wall Street firms, and restricts the flow of information upon which the idea of
capitalism is built. This proposal at it's worst is clearly hypocritical and
smacks of institutionalized legalized "insider trading".
Sincerely,
Gerry Chike
"One of several million common investors"
Author: "Crocker; Ken M" at Internet
Date: 04/24/2000 4:08 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sir/Madam,
Please change the rules to force companies to disclose information on an
equal basis to the general public along with the analysts.
There is no reason why a "free" market should provide any advantages to
people and or firms with money while putting the average person at a
disadvantage. As an individual investor I would like to see the interests
of the average person protected.
Thanks,
Ken Crocker
Orangevale, CA
916-356-5277
Author: "Michael W. Crossman" at Internet
Date: 04/24/2000 8:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Dear SEC,
I am opposed to any change of regulations that supports the distribution of
important company information to Wall Street analysts without simultaneously
giving the news to the public at large.
Michael W. Crossman, MD, PhD
Divisions of Neonatology & Pulmonary Biology
Children's Hospital Research Foundation
Children's Hospital Medical Center
3333 Burnet Avenue
Cincinnati, OH 45229
pH: 513-636-2489
fax: 513-636-2925
email: cro3z@chmcc.org
Author: at Internet
Date: 04/24/2000 7:59 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
I am in support of full disclosure.
As information has become easily accessible in the last few years thanks to
the Internet, it is interesting to note that information has also become more
valuable. Specifically, the speed at which you can acquire and interpret
this information has become increasingly important. The proposed full
disclosure regulation would allow all parties, both professional brokers and
private investors, to have fair and equal access to the information. Without
full disclosure the broker on the inside has a clear and unfair advantage.
I would ask that you implement full disclosure so that all investors can have
free and open access to information about the companies we, the public, own.
Thank you,
Patrick deLeon
Author: Michael Driscoll at Internet
Date: 04/24/2000 6:28 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I think the SCC rules should make info available to everyone at the same
time. No selective disclosure to wall street analysts.
Michael S. Driscoll
40695 Manor House Road
Leesburg, VA 20175
Author: Jennifer Evans at Internet
Date: 04/24/2000 5:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I would like to see information released to everyone at the same time.
Level the playing field please.
Thanks!
Jennifer Evans
AAII
Motley Fool Member
________________________________
Jennifer Evans CCIE# 5417
Cisco Systems
Customer Support Engineer, Lan Switching TAC
Email : jevans@cisco.com
Toll Free: 800.553.2447
Author: "Stephen and Ruth Fairley" at Internet
Date: 04/24/2000 6:35 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
As an individual investor I FULLY SUPPORT the proposed regulation which
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. There
is NO EXCUSE for keeping important information about stocks to the selective
elite.
Thank you in advance for making wise choices that I know will benefit all
consumers--not just the brokers & analysts.
Sincerely,
Stephen Fairley
Author: David Fentem at Internet
Date: 04/24/2000 6:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I strongly support the elimination of the current system of selective
disclosure.
First and foremost, it SIMPLY IS NOT FAIR for some investors, either
corporate or individual, to have access to advance information that can
have a significant effect upon the value of their investments. This is
but one step removed from insider trading.
Please, let's level the playing field. It is not morally correct that a
privileged few enjoy access to information not also available
concurrently to the public-at-large.
In fact, this should be a matter of common sense. It's disturbing that
the preservation of selective disclosure has not been eliminated before
now.
-David Fentem
(Investor, Taxpayer, U.S. Citizen, and Professional Engineer)
Author: at Internet
Date: 04/24/2000 7:33 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am in support of a regulation that will increase the direct flow of
information from companies to individual investors.
Sincerely,
Pamela Gordon
McLean, VA
Author: "M Greer" at Internet
Date: 04/24/2000 7:38 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proprosed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe it is time that us "little" investors have access to the same
information that the big investment community has.
It is in their best intrest to dole out info on their timescale to allow the
"Big Boys" to adjust their portfolios before we have a chance to know the news
is out!
It would be painless for these companies to put this on their website at the
same time they disclose the information to their favorite analysts. Its already
on a computer!
I would take the time to get the facts for myself and I know others can do the
same.
I am still wonder how a company can be rated a "buy" today at 65.00 a share and
2 days later it is "downgraded" at a price of 45.00 with no news that I can see!
Please give everyone equal access to this information.
Thanks,
Mark Greer
Sioux Falls,SD
Author: wynwyn@webtv.net (judie gunter) at Internet
Date: 04/24/2000 8:22 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: LEVELPLAYING FIELD
------------------------------- Message Contents
I am for a level playing field. Why should the big boys get all the
news first. That has never been fair and whomever proposed these new
changes has done the right thing. Jude Gunter
Author: at Internet
Date: 04/24/2000 8:31 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: s7-31-99
------------------------------- Message Contents
Dear "my government,
If I understand this proposed bill correctly, Wall Street gets
information that we
do not. Just whose money do you think us taxpayers are spending when we buy
stocks??? Why should 6 and 7 figured salary people get the benefit of
information when we, the people that buy and own the stocks & mutual funds
don't .
This bill seems to provide a way for the rich to get richer.
I got news for you. WE OUT NUMBER THEM.
JOHN HARRIS
6234 KINGSHIRE ROAD
GRAND BLANC, MICHIGAN 48439
Author: "Jack and Kathleen Hendricks" at Internet
Date: 04/24/2000 6:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To the SEC:
I feel that companies should held responsible for opening access to the public,
the entire investment community, when "guiding" expectations, rather than hold
these meetings with selected analysts.
Thank you.
Jack Hendricks, private investor
Author: "Richard Hergenrader" at Internet
Date: 04/24/2000 5:29 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No. S7-31-99
------------------------------- Message Contents
To whom it may concern'
I think it is about time that the "privileged" information be made available
to the public. Naturally, Wall St. would prefer the status quo. All one
needs to do is watch CNBC for a day and see the "buy" ratings and "target
prices" etc. Do you ever recall seeing a "SELL"?. And lets not forget that
the brokers make money when I buy or sell, not when I make money.
To think that individual investors would not be able to understand this
information is pure hogwash. How many of the managed funds with all their
insider info beat the S&P? It would appear that wall street doesn't do real
well even with this information.
I think the disclosure of this information would make the "analysts" more
accountable. If they serve as valuable a service as they purport then this
should not be a problem for them.
R. A. Hergenrader
Author: at Internet
Date: 04/24/2000 8:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
As an investor I believe that any disclosures by business should be made
available to stock holders and anaylsts and the same time. I am in favor of
your proposal to eliminate selective disclosure.
In addition, I believe that the SEC should also eliminate the practice of
"short selling" stock. In the current market the volatility is such that long
term investors lose out when adverse news is made available and traders "short
sell" driving the price down without "real" investors selling out. In my
opinion "short selling" is contrary to good investment practices. It is
"gambling" short and simple.
The elimination of "short selling" will go a long way to providing a fair
shake for long term investors.
Take care,
Rich Kovacs
1430 Houndsbay Court
Kernersville, NC 27284
336 996 5559
Author: "Ron Krager" at Internet
Date: 04/24/2000 5:11 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I'm am strongly opposed to any regulation that allows publicly owned
companies to provide information to security analysts WITHOUT providing the
same information to the public at large. I am strongly for having companies
provide the same information to all.
Selective distribution of company information is the akin to the
distribution of insider information whereas the analysts get the inside
information and the public gets the "spin" info. Most investors will likely
still use analyst evalutation, but there are many of us that like to judge
the facts and make up our own minds.
Please make the playing field level.
thanks for listening
ron krager
paddler@avicom.net
Author: "Beeuw van Kuijeren" at Internet
Date: 04/24/2000 6:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD. File#S7-31-99
------------------------------- Message Contents
Though I am a small investor I feel I am entitled to the same info at the same
time as the big guys and gals. Beeuw van Kuijeren
Author: howard lee at Internet
Date: 04/24/2000 7:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation CD:File No. S7-31-99
------------------------------- Message Contents
I support proposed changes which would preclude publicly traded
corporations from imforming Wall Street Analysts of news prior to
release of that news to the public...I feel extremely strongly about
this issue...
Howard Lee
102 Bruce Rd.
WAshington Crossing, PA 18977
Author: Shane Lewis at Internet
Date: 04/24/2000 7:37 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I'm very pleased to hear that selective disclosure is being
reconsidered. The public, who are the owners of "public corporations",
should have always had access to information about the companies they
own, not just a select few who then try to manipulate the publics
opinion. This is a very good start to solve a problem that has gone on
too long. Hopefully this will not be the end, as this proposed
regulation is not a silver bullet.
Shane Lewis
Author: Kuang-Yu Liu at Internet
Date: 04/24/2000 6:59 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hi,
I would like to voice my support of your efforts in Leveling the Playing
Field, i.e., the new fair disclosure rules. Keep up the good works. It
is people like who make US the best investment environment in the world.
--
Regards,
Kuang-Yu Liu
Author: "Francis MacLaughlin" at Internet
Date: 04/24/2000 4:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Publicly-traded companies should not be permitted to make selective
disclosure of information affecting stock values to Wall Streeet analysts,
without making the same information available at the same time to the
investing public.
Francis J. MacLaughlin
3648 Surfwood Road
Malibu, CA 90265
Author: at Internet
Date: 04/24/2000 8:05 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Opposition to the changing of rules governing solicitation o
------------------------------- Message Contents
The Securities and Exchange Commission (SEC) is proposing to change the rules
that currently allow companies to give important information to Wall Street
analysts without simultaneously giving the news to the public at large. While
Wall Street is spending big and lobbying hard to keep the current system of
selective disclosure in place, Fools have their own opinions and have been
letting the SEC know where they stand.
Dear SEC Counsel,
I find it disturbing that the SEC would be considering doing the
aforementioned procedure. It is frustrating enought to have brokerage firms
touting "STRONG BUY!!" recommendations to their clients. . .but to permit
them to have information prior to the public? Is this. . .or is this not. .
.a democracy?! I am ardently opposed to the proposition listed above. That
extreme "elitist" thinking in a "democratic" society. The ethical stance the
SEC appears to be taking on this issue is unwarranted. Please refrain from
passing the proposal listed above.
Thank you,
Mark Mayr
Author: JJMerrills@webtv.net (Joseph Merrills) at Internet
Date: 04/24/2000 6:57 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File NO S7-31-99
------------------------------- Message Contents
Level the playing field.
Joe Merrills
Author: "Pete Meyer" at Internet
Date: 04/24/2000 7:38 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File # S7-31-99
------------------------------- Message Contents
Please see that the company revelations are issued to all of the people all of
the time! Thanks!
Author: Bhavesh Patel at Internet
Date: 04/24/2000 5:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Madam/Sir,
As an individual investor, I think the Selective Disclosure should be made
ILLEGAL.
regards,
Bhavesh Patel
Sr. Manager, Database Engineering
650 567 7518
http://www.ventro.com
Author: "Larry Phillips" at Internet
Date: 04/24/2000 8:27 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Having reviewed the proposed rule posted at
http://www.sec.gov/rules/proposed/34-42259.htm, the fact sheet at
http://www.sec.gov/news/extra/sdiscfaq.htm, and the response at
http://www.sec.gov/rules/proposed/s73199/spencer1.htm, I urge you to adopt
the rule as proposed.
The market is most fair and most efficient when full public disclosure
occurs. The internet maximizes the efficient dissemination of information
enhancing intelligent and knowledgeable investing. Although the SIA has
raised some valid points, I believe the practice of selective disclosure
increases the opportunity for manipulation of stock prices.
Larry Phillips
620 W Walnut St
Lancaster, PA 17603
Author: "Price; Bob" at Internet
Date: 04/24/2000 7:33 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I wish to express my strong support for the proposed rule, as an individual
investor.
I'm a part time employee of the Motley Fool, which favors this regulation I
am also a full time employee of BMC Software, though my opinion here is my
own and does not reflect BMC software's -- I have no idea if BMC favors or
does not favor this regulation.
Bob Price
DB2 Performance
<<...>>
Author: "Joe Pruett" at Internet
Date: 04/24/2000 7:19 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Selective Disclosure
------------------------------- Message Contents
Jonathan G. Katz, Secretary,
Securities and Exchange Commission,
450 Fifth Street, N.W., Stop 6-9,
Washington, D.C. 20549.
Re: Proposed Regulation FD - File No. S7-31-99
Dear Mr. Katz:
Please move forward in your efforts to allow equal information sharing to
all investors, regardless of portfolio size. The United States of America
was founded on rights and principles that apply to each of us. Allowing the
continuation of a policy that allows the few to unfairly manipulate the
many, is clearly un-American.
I'm sure that the 45 page document created by the Ad Hoc Working Group is a
masterpiece of persuasion, but is its bottom line an honorable one? My
bottom line is that all of us in the marketplace, risking our hard-earned
money, deserve the same treatment and equal chance to purchase, sell or hold
securities as we wish, using the same available information as the next
person. In this way, individual investors can educate themselves and make
decisions in a more rational marketplace, than one suddenly moved by large
investors privy to inside information.
As more indivduals become better market-educated and choose to invest for
themselves in the future, I believe the cry for equal access to information
will become louder. Again, please allow equal access to market information.
Sincerely,
Joseph D. Pruett III
340 NW 107th Avenue
Pembroke Pines, FL 33026
Author: "MPueschel" at Internet
Date: 04/24/2000 8:23 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Requlation FD: File No. S7-31-99
------------------------------- Message Contents
Michael P. Pueschel
Stop screwing the little guys. DO NOT DISCRIMINATE AND SHOW PREFERENTIAL
TREATMENT with selective disclosure.
Author: at Internet
Date: 04/24/2000 6:59 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
As an individual investor I would like to see information disclosed, in a
timely manner, to everyone, not just the large financial players. I highly
recommend that the proposed regulation for fair disclosure, be passed as a
requirement for all companies to give equal disclosure to the public
investor, at the same time as they are disclosing to institutional managers.
This is one thing that has been overlooked for a long time and should be
corrected. I wholeheartedly support the proposed Financial Disclosure
legislation. With so much increased involvement in the stock market, it is
imperative that laws exist to protect people from business practices intended
to deceive them. Passing this regulation will ensure that the markets are
indeed "free" for all to participate.
Noel Pujol
Decatur, AL
Author: Thomas Pullen at Internet
Date: 04/24/2000 8:26 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
consider this a vote that companies should disclose information
to all people not just wall street
yours,
thomas pullen
Author: Jack Rafferty at Internet
Date: 04/24/2000 4:21 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please make the information available to everyone.
Thank you,
Jack Rafferty
Author: Carol Reese at Internet
Date: 04/24/2000 6:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Information should be for ALLLLLL.. not just "analysts"..... as though
we individual investors are incapable of being "analysts" ourselves if
given lots of information. Yes... open the information floodgates!
Thanks-
Carol Reese
Author: at Internet
Date: 04/24/2000 8:36 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:S7-31-99
------------------------------- Message Contents
It certainly is not fair or ethical for Wall Street or anyone else to be
privy to info on a company ahead of the general public. The prices I pay are
affected if anyone else gets info before I do.
Thank You,
Charles W. Rubbert/Chuck1934@aol.com
Author: asalido@tcia.net (Arthur Salido) at Internet
Date: 04/24/2000 7:48 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am for public disclosure, not selective!
Arthur Salido
Arthur Salido
540-728-5086
Author: noah m at Internet
Date: 04/24/2000 5:28 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Selective disclosure should be ended once and for all.
I believe that everyone should have the right to be
equally informed, not just those who are a part of an
elite "clique". I don't think that this is about
leveling the playing field, because I am adamant to
call the market a game. But rather, the stop of
selective disclosure, would give everyone a chance to
have an individual opinion on what drives the market,
and the economy. Tailoring our opinions to what a
select few think is truly insulting to us.
Rolando Sanchez
Author: at Internet
Date: 04/24/2000 8:38 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation fd: file no S7-31-99
------------------------------- Message Contents
Stop selective disclosure
Vittoria Anastasia Schizas
Author: "Randy K.R. Schmidt" at Internet
Date: 04/25/2000 8:34 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
25 April 00
I support *full disclosure* to *all* persons and companies *simultaneously*
Thank you, Randy Schmidt, P.O. Box 5406, Saipan, MP (USA)
Randy K.R. Schmidt
Author: "Phyllis Snow" at Internet
Date: 04/24/2000 7:06 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am 100% opposed to selective disclosure by the SEC. Selective disclosure to
Wall Street analysts means the SEC becomes SECRET.
Phyllis Snow
466 McKinley
Grosse Pointe Farms, MI 48236
"This message has been prepared on computer equipment and resources owned by the
Michigan Court of Appeals. It is subject to the terms and conditions of the
Court's Compute Acceptable Use Policy."
Author: "Jim Steendahl" at Internet
Date: 04/24/2000 5:58 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The current system of selective disclosure is unacceptable.
Diane Steendahl
Steendahl Enterprises
Author: "Anand Subbaraman" at Internet
Date: 04/24/2000 6:00 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sir/Madam,
I welcome any government requirements that corporations should disclose
information about their company in a public manner (ie: a press release or
some
other kind of open forum). The current system of disclosing select
information to
brokers and analysts exclusively is definitely anti-free market and can
potentially
lead to serious manipulation of the market by controlling information flow.
Open disclosure policies will help level the playing field.
Thank you.
Anand Subbaraman
Author: Todor Trenkov at Internet
Date: 04/24/2000 4:01 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear SEC,
I wonder why is the push to institutionalize another
unfairness in our life! I own a very small portfolio
and enjoy the fact that I can make independent
decisions about my money. Unfortunately, the people
who are already privileged do not like the fact that
someone like me can exercise his brainpower and
independent judgment to be in control of his financial
destiny. I believe that I can take responsibility for
my actions.
I understand that the life of analysts and brokerage
houses is more complicated today due to Internet but
we call this progress. Therefore, any investor has to
have equal access to information from PUBLIC
companies.
It is all about pursuit of happiness!
Sincerely,
Todor Trenkov
Author: "Chris Weaver" at Internet
Date: 04/24/2000 6:16 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I would just like to let you know that I think the proposed rule change, in
which companies must have full public disclosure of relevant financial
information instead of to select professional brokers, is a fantastic idea.
I think professional brokers will still be able to maintain the edge that
they are terrified of losing, while it will help the millions of individual
investors make more informed decisions. What's not to like?
Christopher Weaver
Author: at Internet
Date: 04/24/2000 8:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am a small investor who has all of my retirement money tied up in the
stock market and I am retired and it is incomprehensible to me that as a
stockholder that the management of any company that I hold stock in would
show preference to "insiders" with news about the company that I own a share
of , but that the management does not feel that I am entitled to information
about. the playing field needs to be leveled so that the insider's will not
have such a great advantage , over their customer's in the information as to
when to buy or sell.
SINCERELY
John A. Weaver
1561 JOHNSON LN.
YULEE FL. 32097-4434
JONWEAVER2@AOL.COM
RETIRED UNITED STATES AMERICAN AND NAVY VETERAN
Cc: The Honorable Arthur Levitt, Chairman
The Honorable Norman S. Johnson, Commissioner;
The Honorable Isaac C. Hunt, Jr., Commissioner;
The Honorable Paul R. Carey, Commissioner;
The Honorable Laura S. Unger, Commissioner;
David Becker, General Counsel;
Meyer Eisenberg, Deputy General Counsel;
Richard Levine, Assistant General Counsel;
Sharon Zamore, Senior Counsel;
Elizabeth Nowicki, Attorney;
David Martin, Director, Division of Corporation Finance;
Harvey J. Goldschmid, Special Adviser to the Chairman;
Gregg W. Corso, Counsel to the Chairman.
Author: "David Weiner" at Internet
Date: 04/24/2000 4:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
It is my understanding that the Securities and Exchange Commission (SEC) is
proposing to change the rules that currently allow companies to give
important information to Wall Street analysts without simultaneously giving
the news to the public at large.
HOORAY! FOR THE PROPOSED CHANGES. Big brokerage analysts have had this
unfair advantage long enough. Here are some of my thoughts on the issue:
- Public company information should be equally accessible to both Individual
investors and institutional investors and the Wall Street firms that
represent them. There is no VALID reason why certain analysts should get
privileged information.
- Professional Analysts serve a very important function in that they often
make cohesive sense of specific tidbits of information. However, many
individuals may prefer to do their own analysis, or rely on both the
information coming directly from companies and the analyses coming from the
Analysts. Many individuals will still rely on Analyst's reports for company
information, but providing equal access will give individual investors this
choice, and provide them with a means for evaluating skill levels of these
analysts.
- The market is an efficient system, and the more freely information flows,
the more efficient the markets will be. If volatility is a byproduct of
efficiency, then so be it. If Analysts and Professional Wall Street money
advisors have the ability to navigate more successfully through the markets
with EQUAL access to information, then they will end up with their fair
share of investor funds to manage.
- The only practical argument I have heard in support of the current system
is that a few qualified analysts are better able to ask appropriate
questions to better ferret out the most relevant and revealing information.
However, this is arguable. By their nature, Analysts have an incentive to
maintain positive relations with companies, otherwise they may not be privy
to the preferred information in the future. Perhaps there is a way to have a
few select individuals (some of which could be professional Analysts) on the
front lines of these company information exchanges.
Selective Disclosure is unfair to individual investors who in large numbers
are becoming more directly involved in the market and relying less on both
transactional and informational intermediaries. Today's information age
makes obsolete Selective Disclosure which only serves to line the pockets of
the Good Old Boys of Wall Street.
Thank you for your consideration.
David Weiner
Product Director
The Meyers Group
858-792-8276 ext. 238
Author: "Dale Yakin" at Internet
Date: 04/24/2000 3:56 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD: File No. 57-31-99
------------------------------- Message Contents
Dear Sirs,
In regard to this rule and the many debates taking place, let's remember
that most investors will not try and value companies unless they have a firm
grasp about how valuations should be performed.
With something as important as retirement, very few people will test their
luck with something that they do not understand or have an interest in
doing. When was the last time you tore down your car engine? Surely you
don't fear the depth of knowledge required, you're just willing to pay an
"expert?" to handle it for you. Most investors will continue to pay brokers
to handle their accounts.
Secondly, how many brokers do you know personally? I know quite a few, and
only one major brokerage house requires them to be finance majors in school.
Most of them know very little about business strategy and valuation.
Investment houses can always fall back on the argument that that their
brokers are merely representatives who pass on the information that is
compiled by their analysts and made available in "buy lists". This belief
is narrow-minded tunnel vision. These young brokers make an average of 200
humiliating cold calls per day to find one new client. The first time they
lose a client because one of the stocks in this list under-performed is also
the last time they use the list as any more than a possible lead. They end
up choosing their own stocks.
The perception at many of these investment houses is also manufactured. At
one very well known firm, a broker gets his own office and assistant not
because his clients' accounts performed well, but because he brought in ten
new accounts every month for his first 15 months on the job. He is rewarded
because he knows people, has a big family, or is a good salesman. There is
absolutely no tie to his performance as an investor.
I have an MS, an MBA, I've partially completed my CFA, and I know that I can
understand and utilize business information to make investment decisions
better than the great majority of brokers. To deny me this information is
no more than greedy corruption.
Sincerely,
Dale Yakin
http://www.sec.gov/rules/0424b03.htm
