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U.S. Securities and Exchange Commission

Comments on Proposed Rule:
Selective Disclosure and Insider Trading

Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99


Author: "Anderson; Ethan" at Internet Date: 04/25/2000 9:50 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To Whom it May Concern: This proposition is a terrible one, and should not be allowed to pass. Individual investors like myself would be at a great disadvantage if this goes through. Thank you. Ethan Anderson Senior Support Analyst Continental Airlines 713.324.9066


Author: "Andler; Eliot [And]" at Internet Date: 04/25/2000 11:56 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please put an end to selective disclosure. Please level the playing field by forcing companies to disclose information - important to the individual investor - in a more equitable manner. Eliot S. Andler


Author: "Simon Mawby" at Internet Date: 04/25/2000 8:44 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Madam/Sir I am writing to voice my support for Proposed Regultion FD. I feel very strongly that individual investors have the right to the same quality of information as Wall Street analysts. The idea that "analysts cannot do their work nearly as well as they do now if they are forced to do their work, at least when it comes to interaction with issuers, collectively -- in a pack" (from the Securities Industry Association's filling in opposition) is ridiculous. How would a more open environment prohibit a diligent analyst from "relentlessly pursue an independent line of inquiry and ferret out negative information that management would rather not disclose or would prefer to disclose at a time of its choosing and with its own spin" (SIA filling). It seems to me that they would like to keep a lock on this information in order to keep individual investors dependent on their services. Thank you for your consideration, Gina Atwood Independent Investor


Author: David at Internet Date: 04/25/2000 8:05 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No.S7-31-99 ------------------------------- Message Contents It is imperative that laws like this are in place to keep businesses in check. The "public" does not need protection from themselves. Do you really believe that only a chosen few understand the market and that they have the "public's" best interests in mind? I think not! This is the US, not some communist country, where the information available to the "public" about "publicly traded" companies should be edited for our own good. What the analysts and Wall Street are afraid of is that we DO understand what they disclose and then we will NOT INVEST in the companies that they want us to! Please pass this law. C. Bell Small Business Owner


Author: Jesse Brandeburg at Internet Date: 04/25/2000 8:58 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I would like to have the selective disclosure laws abolished! I believe fair access to ALL information should be available to ALL investors at the same time. Thank you, Jesse Brandeburg --------------------------------------------------------------------------- jesse_brandeburg@bigfoot.com


Author: at Internet Date: 04/25/2000 11:29 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sir/Madam: I am writing to encourage you to revise your rules to require public companies to give information to the public at large at the same as they give it to professional analysts. I especially enourage you to consider the experiences of public companies who already widely volunteer such information, and to consider how analysts themselves have been and are being decentralized, how individual investors already *reference* analysis and commentary from a number of sources, such as TheStreet.com or The Motley Fool, to help make investment decisions. I believe that such an orientation of investor in the center and advisors on the periphery is the healthiest and most prosperous arrangement. Concerns about overwhelmed individuals are misplaced, I believe, because it is always the person putting down the money who actually makes the decision anyway. Changing your rules does not alter that basic fact, but only changes the center of gravity--a process already well underway with online trading, for example. As such, I believe full and fair public disclosure is an inevitable movement that is best embraced rather than resisted. I believe that technology has made it possible for all such information to be distributed readily, and believe that people are increasingly capable of understanding the issues involved. Moreover, there are a multitide of services available to individuals, offering commentary and education on financial issues, to further aid in the assimilation process. Such a change in your rules, I believe, would only help our system of markets prosper by continuing the movement of individual responsibility and opportunity started with the founding of this country, and most recently enhanced by the advent of the PC and now Internet. In short, I believe that companies that make information available only to analysts tend toward wanting to control or spin how that information is digested. That understandable desire, however, conflicts with the basic fabric of our markets, which provide opportuntity for companies and investors while providing an accountable and level playing field. In this regard, I believe lobbying efforts to keep the rules as they are primarily arise out of a status-quo mentality that is inadequate and perhaps even dangerous to the vitality of our world-leading markets. Again, I strongly encourage you to change your rules to require all public companies to divulge information to the public at large. Thank you for your consideration, Sean Bronzell


Author: "Jonathan Cohen" at Internet Date: 04/25/2000 11:07 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I support the proposed regulation. -Jonathan Cohen Department of Philosophy office: (732) 445 6163 Faculty of Arts & Sciences home: (718) 499 1213 Rutgers University email: joncohen@ruccs.rutgers.edu 26 Nichol Avenue snail: 295 7th Avenue #3 New Brunswick, NJ 08901 Brooklyn, NY 11215 http://ruccs.rutgers.edu/~joncohen/cohen.html


Author: "Hamid and Connie L. Daie" at Internet Date: 04/25/2000 9:05 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please open up the process for the little guys, and let us have access to financial information the same time that the fat cats in wall street access such information. Sincerely, Hamid Daie


Author: "Keith Davidson" at Internet Date: 04/25/2000 9:18 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Brokers and other professionals should NOT have company info before the investing pulblic. My IRA acount is more important than some company's profit. They make money at the public expense. I am considering contacting my congress person about this. Keith Davidson


Author: "Day; Thomas (STP)" at Internet Date: 04/25/2000 10:09 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents The Existing regulation is a terrible idea, both for the economy and for the market. The so-called "experts" in the market have done nothing to deserve a special advantage over the public. With the dramatic increase in private investors, through the internet and discount brokerages, the market has changed and the proposed regulation reflects that change. Thank you for providing leadership with this rule change. Thomas Day 2660 Lake Shore Avenue Little Canada, MN 55117


Author: "David DeCurtis" at Internet Date: 04/25/2000 11:27 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am in favor of fair disclosure.  I do not need or want to wait for an analyst to decide what I should do with my holdings.  The current system of privileged disclosure is a shameful assault on the rights of small minority shareholders of public companies.   David DeCurtis Orlando, FL


Author: cdoersom at Internet Date: 04/25/2000 11:02 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I support fair disclosure rules. Wall Street analysts should not be given unfair advantages. The time to level the playing field is long overdue. Carol Doersom Corning NY


Author: at Internet Date: 04/25/2000 11:27 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe all americans deserve accessability to the same information provided to the finacial institutions. Please pass the appropriate legislation to allow this to happen. Thank You, Mark H. Downey 29652 Avante Laguna Niguel, CA 92677


Author: "Dick Dragiewicz" at Internet Date: 04/25/2000 9:51 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Individual investors want an equal opportunity program. Wall Street houses don't deserve special treatments. Thanks, Dick Dragiewicz 312-444-9503 obiobiobi@msn.com


Author: "Josh Gatts" at Internet Date: 04/25/2000 8:03 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To whom it may concern: I am writing to express my support for Proposed Regulation FD. I believe that individual investors have the right to obtain any information released by a company at the same time as professional market analysts. The Securities Industry Association's arguments against the proposal pretty much boil down to, "The public can't be trusted with this information. They need us to interpret it for them so that the market will remain stable and efficient and they won't lose lots of money with their random, uneducated investing practices". This is sheer, elitist nonsense: it is completely undemocratic to allow well-positioned members of some old-boy's club access to important data while denying it to the public at large. There are many intelligent, free-thinking individual investors out here that would benefit greatly from corporations' legal obligation to disclose information nonpreferentially. There is no reason to think that giving analysts privileged information somehow makes the market more efficient or stable: all it does is allow them to act on knowledge before it is disseminated to the general public. The SIA's stance is a transparent cover for their real motivation: to maintain analysts' job security as well as to maintain an advantage for themselves and their wealthy clients. Thank you for your attention to public comments on this issue. I hope we will see Regulation FD passed in the near future. Joshua Gatts Hayward, California


Author: bob gib at Internet Date: 04/25/2000 8:37 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: FIle No.S7-31-99 ------------------------------- Message Contents Please level the playing field for all investors. Stop letting the rich get richer at the expense of the little people. I am a little investor and have never used an analysts recommendation for investing in any stocks. It makes me sick when I hear analysts upgrading a stock after they have already purchased the stock for their customers. It's like knowing the final score of a game before it even starts .These analysts want to stay in the driver's seat so they can reap the rewards of advanced knowledge. It's just not fair to all investors. If you want to make if fair don't allow the analysts to make their recommendation public,allow them to give info to their paying customers only. You are allowing a certain group of investors an enormous advantage over another that's not fair. Robert Gibbons Bethpage NY


Author: "G R Glore" at Internet Date: 04/25/2000 10:30 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents We are for Full Disclosure to Public Gary and Rita Glore 11 Donald St Park Hills, Mo. 63601


Author: Duncan Granger at Internet Date: 04/25/2000 11:03 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To the SEC, As an individual investor, I take exception to some of the comments made on April 6, 2000, by The Ad Hoc Working Group on Proposed Regulation FD and the Legal and Compliance Division of the Securities Industry Association ("SIA"). Fair Disclosure - disclosure to the public at large, not limited to certain analysts - should be required by law. We live in a democratic society. Information is power. If a company is publicly traded, it should provide ALL information to the public at large. Restricting information to certain analysts creates an atmosphere of collusion. It also insinuates that individual investors cannot understand the level of information provided to analysts. The SIA asserts that it is "highly theoretical and out of sync with the real world" to think that "millions of individual investors and potential investors" would spend time "poring over prospectuses and periodic reports." I currently subscribe (for free) to an e-mail service through freeedgar.com whereby any time that a company in which I hold stock files a report with the SEC, I am notified by e-mail. I can then choose what to read and what not to. I would suggest that the SEC look at the number of "hits" received at sites like freeedgar.com to gauge the public interest in accessing this information. I do not find it AT ALL far-fetched to think that millions of individual investors may already be researching thoroughly the companies in which they own stock. Fair Disclosure would simply level the playing field, and give COMPLETE information to the individual investor. In addition, the SIA suggests that Fair Disclosure would lead to "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." I don't even know where to begin with this one. This conjecture is so farfetched as to be laughable. Does the SIA know so much about publicly traded companies that they can predict how future meetings will be run? This is a scare tactic, pure and simple. The SIA is trying to scare individual investors into thinking that Fair Disclosure would actually result in less information being released to the public. Who among us can accurately predict, at this point, the type of meetings which issuers would hold if the Fair Disclosure act were passed? I could just as easily predict that these sessions would result in the asking of new and different questions which would never have been asked under the current format. The SIA seems to be desperately trying to justify its own existence. The SIA knows that analysts cannot predict the direction of a stock with any more accuracy than a self-taught individual investor. Knowing what questions to ask so that someone can "ferret out" negative information is not a gift from God granted solely to analysts. As a matter of fact, analysts seem hesitant to make negative statements about a company (lest that company need financing a year or two down the road, and refuse to do business with the analysts employer because they remember the negative comment). How often does one see an analyst assign a "sell" rating to a stock? Individual investors are not children. They do not need to be protected. Let them make their own mistakes. Certainly they cannot do worse than the analysts, whose recommendations have guided over 90% of mutual fund managers to UNDER PERFORM the market in recent years. Fair Disclosure is overdue. It needs to be enacted now. We live in a free, democratic country. If a company wants to be traded publicly, it has a duty and obligation to the citizens of this country to provide all relevant information to the public at large, not just to a select few analysts. Respectfully submitted, Duncan M. Granger, M.S. 40 North Lime Street Lancaster, PA 17602


Author: "Dylan Groven" at Internet Date: 04/25/2000 10:26 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I see no justifiable reason why some information regarding publicly traded companies should be disclosed only to a select group of analysts. Let the information be disclosed to everyone and allow the gifted analysts to prove their worth without hiding behind a curtain of secrecy. -------- Dylan Groven Nortel Networks Department 1U38 ESN 395-4434 (613) 765-4434 dgroven@nortelnetworks.com


Author: "Barbara Haugen & Charles Widdicombe" at Internet Date: 04/25/2000 9:58 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I have been investing in the market for 20 years. The last few years I have been doing so through a discount broker. By handling my own investments, I have greatly improved the rate of return. The amount of money that we have to invest just isn't very enticing to a full service brokerage. We don't have enough money to warrant their best service. I watch my stocks far more closely than anyone else ever has. Those of us without much money to invest can participate more fully in the market, pursue our version of the "American Dream" if you will, in large part because discount brokers don't eat up what little we can invest with fees. I am still just as much an owner of these companies as anyone else. You will be deciding shortly what ownership rights we have. Does owning more stock, in essence having more money to invest, make you "more equal" in the eyes of the SEC? How will I ever be able to participate fully until I am allowed equal access to information? To be redundant, if I buy 20 shares of a company in which someone else can afford to purchase 2000 shares, they should not get access (through their broker) to information before I do. By allowing companies to pick and choose what information they disclose and to whom, you would be reinforcing the idea that the stock market is only for the wealthy. I left full service brokerages so that my money will grow. When full service brokerages get information before the rest of us, they use that information to manage clients' accounts. By continuing to allow selected disclosure you would, in essence, be allowing unfair advantage to those with wealth...not at all an American ideal. Sincerely, Barbara Haugen


Author: "Haze; Paul" at Internet Date: 04/25/2000 11:06 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents I for one would like to see full disclosure on all meetings held between analysts and any Company (That is where more than one analyst is meeting with the company ). I would also like to have the opportunity to ask or submit questions to be asked at the meeting. I do not think I have the right to attend or even listen in to "Live coverage" but should be brought up to date in a timely fashion. I feel analysts do have the right to Private meetings (one on one) just as I have the right to call the same company and ask the same or similar questions. I strongly feel that the information should be disclosed to the public, by the company, in a timely fashion. Paul Haze


Author: at Internet Date: 04/25/2000 11:49 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear sirs: Throughout human history, those enjoy special privilege -- whether in power, wealth, or access to information -- usually seek to maintain their advantage over others. When forced to publicly defend their superior positions, they use elaborate arguments, most of which boil down to the following: 1. others are incompetent and must be "protected" by the existing elite 2. any change in the current pecking order will be destabilizing 3. democracy will lead to chaos and ruin These arguments are lies. For all the inequities of human nature, this country remains the best hope humanity has for the creation of a society that can be rightly be called fair, just, and equitable. Please: LEVEL THE DAMN PLAYING FIELD. I strongly support the proposed reform regulation to do away with selective disclosure. Sincerely yours, Bill Herbst individual investor


Author: at Internet Date: 04/25/2000 11:54 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD:File No. S7-31-99" ------------------------------- Message Contents I am voting for full disclosure to the public. CASSANDRA Y. HOLLEMON


Author: "Gregory D. Johnson" at Internet Date: 04/25/2000 10:39 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: S7-31-99 ------------------------------- Message Contents It is time for the SEC to require companies to give its smaller shareholders the same information, at the same time, as large institutions. You can look at many stocks and see that you are too late to trade on the information because it appears that others know the information earlier than you do. The other disturbing area is the selective audience for conference calls. One example that I know of and that I have a large investment in is Snap-on Incorporated (SNA). The never give out the number to their shareholders and at the end of 1999, the number wasn't an 800 number. I believe that this discourages investors from listening to the call. The playing field needs to be leveled. Gregory Johnson


Author: Bob Kendall at Internet Date: 04/25/2000 7:59 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Gentlemen: Please count my voice in the chorus of those in favor of the subject regulation. I am a private investor with no professional tie to the financial community, and I find it appalling and arrogant that the purported experts in the field of investing feel that we cannot understand and filter raw corporate data on our own without their expert analysis. (Keep in mind that it was many of these same experts that first started telling us it was time to "buy on the dip" in early March of this year.) No, thank you, I feel quite capable of digesting market data on my own, and making my own decisions without Wall Street's assistance. While I've got your ear, I might suggest two other areas that you might want to consider: 1. Anybody calling him/herself an "analyst" should have to publish their personal portfolio. 2. You have got to put a stop to the "whisper number" nonsense. Either these people have an earnings number that they believe, or they don't. Publishing one number and then going around "whispering" another is the most cowardly approach to that job that I can imagine. Thanks in advance for taking the time to consider my opinions, Bob Kendall 1742 Bonaire Way Newport Beach, CA 92660 949-642-7510


Author: "Billy King" at Internet Date: 04/25/2000 11:07 AM Normal TO: RULE-COMMENTS at 03SEC Subject: File S7-31-99 ------------------------------- Message Contents We who are managing our own portfolio are entitled to the most complete information available. Brokers have long tried to keep everything close to chest but it is high time all info was shared with the people purchasing the equities. Make all available to us.


Author: "Korb; David" at Internet Date: 04/25/2000 8:56 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear SEC : As an investor in publicly traded securities, I feel I have stake in your proposed regulation File No. S7-31-99. It is manifestly unfair that analysts and market makers be given information on publicly traded companies which is not readily available to all investors. The market is "efficient" in that the price of a security accurately reflects all of the information about that security. To give information to one group and allow that group to disseminate that information to the rest of us is wrong. That is the kind of control that a loving parent has over their children. A child needs to be protected by their parent. Well firstly, I am not a child and do not need to be protected from myself. And secondly, the analysts are not "loving parents" - they have their own special interests, and frankly should not have this control. Please open access to publicly traded companies to ALL investors. David Korb dkorb@sempra.com


Author: "ELN/lavayerobert" at Internet Date: 04/25/2000 9:32 AM Normal TO: RULE-COMMENTS at 03SEC Subject: PROPOSED REGULATION FD: FILE # S7-31-99 ------------------------------- Message Contents CONGRATULATIONS: IT'S ABOUT TIME THAT THE SEC TOOK SERIOUS STEPS TO LEVEL THE PLAYING FIELD FOR THE INDIVIDUAL INVESTOR TO HAVE THE SAME DATA AT THE SAME TIME AS THE LARGE BROKERAGES. IT IS WELL KNOWN THAT THE BROKERAGES HAVE BEEN MANIPULATING THE MARKET BY HAVING THEIR ANALYSTS DEPRESS SPECIFIC MARKET SECTORS WITH THEIR GLOOM & DOOM PREDICTIONS. ONLY TO BUY LARGE BLOCKS OF THOSE STOCKS FOR THEMSELVES & THEIR INSTITUTIONAL PLANS, ARMED WITH INFORMATION RELEASED TO THEIR ANALYSTS BY COMPANIES PRIOR TO THE PUBLIC HEARING ABOUT THE NEWS. CONSEQUENTLY, THE INDIVIDUAL HAS EITHER MISSED THE UPWARD MOVE, OR BEEN CAUGHT IN THE DOWNWARD MOVE. IN EITHER EVENT. THE INDIVIDUAL INVESTOR HAS BEEN THE LOSER, WHILE THE INSIDERS HAVE MADE MAJOR PROFITS. IT'S BAD ENOUGH THAT THE DAY TRADERS HAVE FORCED LARGE DAILY EXCURSIONS IN STOCK PRICES, THRU QUICK PROFIT PLAYS, WITHOUT THE BROKERAGES AMBUSHING THE INVESTORS WITH THEIR PREMEDITATED TACTICS. LET'S GIVE THE INDIVIDUAL INVESTOR THE TOOLS NECESSARY TO MAKE A CALCULATED DECISION TO PROTECT THEIR PORTFOLIOS. THANK YOU, Robert C. LaVaye


Author: Ann MacArthur at Internet Date: 04/25/2000 8:20 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Ladies and Gentleman: I would like to add my comments to those already made regarding selective disclosure rules. Any potential change to open up the stream of information going to individual investors, is, I think, a good one. Having been an investor in the market for a number of years I have valued the increasing information that is available through the web and other sources over the years. I find that individual investors are a smart group who like to pay close attention to the companies that they have invested in and are able to make their own decisions about the importance of certain announcements by companies. Those companies that respect the individual investor enough to provide information to all benefit by increased investor confidence. To level the playing field by eliminating the current system of selective disclosure is a move that I support and that many individual investors I know will appreciate. Thanks for your time, Ann MacArthur anncm@earthlink.net


Author: "Carol Marquess" at Internet Date: 04/25/2000 8:10 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I spent more than fifteen years in the finance industry (commercial banking and some investment stuff) and was continuously amazed at the amount of insider info and inappropriate division of information that was offered to us, as opposed to the general stockholder community. Please adjust the reg to insure fairer and across the board treatment for all investors!


Author: Carole McMurray at Internet Date: 04/23/2000 12:49 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD File # S7-31-99 ------------------------------- Message Contents The public should be informed at exactly the same time as analysts & brokerages. Dennis & Carole McMurray


Author: "Kathy" at Internet Date: 04/25/2000 8:12 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No s7-31-99 ------------------------------- Message Contents If this is not passed then all information companies get should be classified as insider trading and they should not be able to act on it. Kathy Mettler


frances@mashell.comAuthor: meg parsons at Internet Date: 04/25/2000 9:07 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents As an Investor I am appalled that you would even consider allowing someone to have information before the General Public. Meg Parsons


Author: "Bruce O" at Internet Date: 04/25/2000 11:52 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am in strong support of this regulation to stop information transfer to analysts and no the public. Bruce Ostrout MediaPipeline


Author: at Internet Date: 04/25/2000 11:53 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File NO. S7-31-99 ------------------------------- Message Contents level the playing field. walter pearce


Author: at Internet Date: 04/25/2000 11:01 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sir or Madam: As an individual investor, I applaud and look forward to the referenced proposed regulation becoming law. It is consistent with the tenant of "freedom of information" that has and will continue to help reinforce our nations commitment to freedom and economic progress. Thank you. Eric Prim 3707 W. Glen Dower Dr. Fredericksburg, VA


Author: at Internet Date: 04/25/2000 11:46 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am greatly in favor of eliminating selective disclosure by companies to analysts before release to the general public. Burton M. Sapiro 2804 Fairway Drive North Jupiter FL 33477


Author: res at Internet Date: 04/25/2000 11:05 AM Normal TO: RULE-COMMENTS at 03SEC Subject: FD File #S7-31-99 ------------------------------- Message Contents Dear Mr. Katz, I am writing to express my approval of the proposed regulation "Regulation FD: File No. S7-31-99." As the markets open up to more individual investors, thanks to the explosion of on-line trading and self-service brokerage accounts, it is more important than ever that information be allowed to flow freely and quickly among market participants, to include individual investors. As an individual investor, I have the majority of my retirement funds in stocks. I feel that I should have the same information available to me as analyst from Brokerage firms. If I am unable to understand the information presented, then I have the option of attaining a broker to help me. I am a Realtor, and by law we are required to let buyers and sellers know who we represent and have to provide disclosure of material information to prospective buyers. I feel as a investor I should have that same right. If we are unable to obtain the same information that is available to brokerage companies, you are denying the public the right to know and in my opinion are stacking the deck in favor of the brokerage companies. I sincerely hope that you will come down on the side of fair play . Thank you for the opportunity to express my opinion. Rodney E. Sawyer 63 Shore Rd. Otisfield, Me. 04270


Author: "Glenn Shelby" at Internet Date: 04/25/2000 9:53 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sirs, I urge you to adopt the Fair Disclosure regulation. With the rise of internet stock trading, the days of broker controlled trading are waning. The individual investor deserves to have access to the same information that only a select few currently enjoy. Please adopt this regulation. Thank you, Glenn A. Shelby


Author: "Smith; Robert W" at Internet Date: 04/25/2000 10:18 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please accept my wish that this regulation be passed. I do not feel that analysts are necessary to interpret company data before it gets to individual investors. I want the same information available to me as the analysts have. Level playing field and all that. Robert W. Smith - Agent American Family Insurance 1721 W Elfindale Ste 304 Springfield, MO. 65807 Phone: 417-831-3699 Fax: 417-831-3812


Author: Alan Stange at Internet Date: 04/25/2000 11:00 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Hello, I wanted to take this time to write in support of the fair disclosure rules. I consider the arrogant attitude of many Wall Street analysts to be somewhat shocking. Frankly, I don't know anyone that listens to analysts on Wall Street when making investment decisions; the reason is that most analysts provide rather biased information. At at time when the President is considering placing Social Security investment options at the hands of individuals, the SEC should be empowering individuals to make their own decisions. We don't need protection from the government or from analysts on Wall Street to make our own decisions...and our own profits. I consider the whole notion of selective disclosure to be rather insulting. Dr. Alan Stange


Author: Sara Swafford at Internet Date: 04/25/2000 8:33 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I'm just a individual investor trying to build a retirement. Companies releasing information should release to the public at the same time as the wall street analysts. Sara Swafford


Author: at Internet Date: 04/25/2000 11:21 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents SEC: I hope that you will put the proposed regulation in effect. It is unfair and discriminatory to other investors to have important stock information released to a selected few who profit upon it at the expense of the rest of us. Joan M. Sweeney


Author: "Tolley; Eric [Act 1]" at Internet Date: 04/25/2000 10:07 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99, Outhere Productio ------------------------------- Message Contents I believe that full disclosure is the only way to ensure free and fair trade. The current system is designed simply to line the pockets of a few individuals and "protect" the public from its self. Personally I do not believe that I am in need of protecting. Thank you for your time, Eric Tolley CEO Outhere Productions


Author: "Trapaga; Carlos [MCCUS]" at Internet Date: 04/25/2000 11:29 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To Whom It May Concern: In the interest of fairness, I beleieve information should flow to all people/companies/concerns equally and without editorial content. Then, whomever wishes to use the information in whatever fashion, may do so at their own risk. Otherwise, we should be indemnified of risk by well intentioned but incorrect analysts who draw wrong conclusions. The model for this is a a lawsuit brought against a doctor who misreads or misdiagnoses a test result, and subsequently prescribes an incorrect remedy to a patient. I do not believe Wall Street can or should have it both ways, either withold the information and be sued for misreading the signs, or opwen informatrion access to all and accept the outcome. By the by, the only places where information is witheld and "edited" are called Communist/Totaitaria, and not a place one is considered to wish to be. CTrapaga@hotmail.com


Author: "Jerome Travers" at Internet Date: 04/25/2000 11:54 AM Normal TO: RULE-COMMENTS at 03SEC Subject: proposed regulation fd:file no.s7-31-99 ------------------------------- Message Contents For proposed regulation FD:file no. s7-31-99 Hey,it's OUR government , not some collection of companies and bureaucracies.. thank you Jerome Travers


Author: hrgcinfo at Internet Date: 04/25/2000 11:57 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I find it appalling that the SEC would even consider not supplying information to any and all interested parties. Why require companies to provide a prospectus? Why require 10K filings? As more and more investors make use of online (instant) data, they only become more knowledgeable about what they do and how they do it. The world is changing and FD S7-31-99 is about keeping up with those changes. Please vote for this proposal. Keith M. Vincent, CPA


Author: at Internet Date: 04/25/2000 11:23 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Reg FD: File S7-31-99 ------------------------------- Message Contents As an investment advisor, I see first-hand what happens when a company first discloses information to analysts before the public. I get calls wondering why I did not get the news faster! If we're to have public confidence that there are favored investors out there, all companies must disclose their information to all, at the same time, through a public vehicle like a press conference. Tom Waymire, President Yield Management Company, LLC


Author: "David Wierda" at Internet Date: 04/25/2000 10:58 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Hello to you all! Please change the law to make for fair disclosure to EVERYONE. As someone outside the whole securities industry, I cannot understand why some information of publicly traded companies has to remain the right of the people who make money off other people by using that information. When in the history of the United States have we believed that the common good is best served by less rather than more disclosure? I know you can find special examples where that might be true or appear to be true. I do not for a minute believe that this is one of those cases. Thank you. David http://ourworld.compuserve.com/homepages/DavidWierda


Author: "J. WITT" at Internet Date: 04/25/2000 8:45 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No.S7-31-99 ------------------------------- Message Contents As an 10 year veteran of the markets, I am outraged over the "country club" nature of selective disclosure. The loose rules and regulations surrounding this "perk" has enabled big-money investment bankers, hedge funds, mutual funds, etc... to reap god-like profits at the expense of individual investors. The SEC's unwillingness to equitably regulate this part of the investment community is a disgrace and belies the fact that the foxes are guarding the hen house. Mr. Levitt, regardless of his assertions to the contrary, rarely punishes the large broker, banker, company, etc... for violating standing SEC law. Instead, the SEC pounces on the small fry individuals destroying the life of a delivery person or secretary for trading 500 shares based on an internal memo they found. Bravo! Meanwhile, Mr. Levitt's "friends" skim, steal, and inside trade hundreds of millions or even billions of dollars with impunity or with little more than the threat of a $50,000 fine and no-contest out of court settlement. Protect your own... right Mr. Levitt, all in the name of free markets! Give me a break. The selective disclosure issue is one of many insular reforms that could be easily and quickly changed. Unfortunately, lobbying and soft-money pay-outs and "loans" to decision makers by the benefactors of selective disclosure will likely mean no change. The health of the entire market is at risk without reform of selective disclosure. To let a few let a few benefit at the expense of many is reprehensible. As the internet information wrecking ball continues to barrell through the markets, greater pressure will continue to be exerted by individuals like me who demand an level playing field. Hopefully, the SEC is smart enough to get ahead of the curve and be pro-active and not reactive. For the markets to grow and be healthy, reform is absolute but knowing how middle-aged white males want to protect their own "good thing" I am not expecting much...except for a change of leadership with someone with balls enough to do the right thing. J. Witt


Author: Laureen Biczak at Internet Date: 04/25/2000 10:50 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Sirs, I am strongly in favor of proposed rule changes to force companies to give important information to all investors, rather than selectively to institutional investors & brokerage houses. The current system is inherently biased & unfair, and is contrary to the principal that all investors should have equal access to company information, regardless of the size of their investment position. Your failure to pass this proposed change in regulations will damage your credibility to the small investor & to the general public, adding to the perception that the large brokerage houses hold undue influence over the SEC. As an active individual investor, I expect the SEC to represent my interests equally with those of the large brokerage houses. Sincerely, Scott Woodside


Author: "Jairo Yun" at Internet Date: 04/25/2000 11:44 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents The public should get information at the same time the analysts do. It is only fair. Jairo Yun

http://www.sec.gov/rules/0425b04.htm


Modified:05/09/2000