Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "RCBarto" at Internet
Date: 04/27/2000 2:03 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Disclosure
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All investors should have access to the same information at the same time.
Analysts getting special briefings is just inviting insider trading. As an
investor I should have the same opportunity to buy well or sell well as
anyone else.
Cordially,
R. Clark Barto, Investor
Author: at Internet
Date: 04/27/2000 12:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: selective disclosure
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As a committed stockholder who trades regularly and does my DD I feel cheated
not to have the information analysts are given that influence their decisions
that I would not be privy to in a timely manner.
SINCERELY,
Mason Batchelder
Author: Rick Brooks at Internet
Date: 04/27/2000 12:47 PM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD
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I strongly support the implementation of regulation FD. I am a candidate
for Chartered Financial Analyst, a registered rep with the NASD (Series 7
and 66), and a representative for RunMoney.com. I believe that the current
system of disclosures only to analysts is unfair and results in the
perception of preferential treatment for large wall street firms.
I am responding on my own behalf, not on behalf of my company.
Sincerely,
Rick Brooks
Investment Advisor Representative
RunMoney.com
858.509.9560 x136
rickb@runmoney.com
Author: "dick davis" at Internet
Date: 04/27/2000 11:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File No. S7-31-90, Ellenar Associate
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Fairness should dictate public inclusion! Richard Davis
Author: at Internet
Date: 04/27/2000 9:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed reg fd: file no. 57-31-99
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I am in favor of simultaneous news to the public at large...
Thank you
James H Davis
P O Box 4693
Newark, DE 19715-4693
Author: Steven Destefano at Internet
Date: 04/27/2000 11:29 AM
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BCC: RULE-COMMENTS at 03SEC
TO: rule-comments@sec.com at Internet
Subject: Proposed Regulation FD: File No. 57-31-99
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To whom it may concern:
I am writing as a private citizen/investor. Please change the rules
that currently allow companies to give important information to Wall Street
analysts and large institutional investors without simultaneously giving
the information to the public at large. It is grossly unfair that this
situation should exist, and should be corrected.
Sincerely,
Steven A. DeStefano
10838 Sonora Ave
Alta Loma, CA 91701
Author: "Sally Dillon" at Internet
Date: 04/27/2000 7:14 PM
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TO: RULE-COMMENTS at 03SEC
Subject: file #57-31-99
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4/27/00
To Whom It May Concern:
I am in full support of the proposed regulations to eliminate selective
disclosure.
I have had very bad experiences as a shareholder of Budget group, "symbol
BD". The company has lost in excess
of 85% of it's share value. There have been numerous times that I have
witnessed the shares plummeting in price, only
to discover missed earnings, additional losses or substantial restructuring
charges, which were known to Wall Street,
but not to me as an individual shareholder.
This company is controlled by a select few who have "super voting" powers.
I am trapped in my huge losses with no voice as a shareholder and no access
to critical information on a timely basis.
I hope you will consider the elimination of super voting shares, as well.
Budget Group is an example of how these privileges are used to thwart the
will of the shareholders.
Regards,
Sally Dillon
561-778-8388
Author: "Ad Dugan" at Internet
Date: 04/27/2000 6:46 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Wall Street Information
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It has come to my attention that you will be voting on a rule tomorrow dealing
with whether or not Wall Street can continue to "filter" information that it
recieves about different companies.
With the number of people with money in the stock market, it is inconceivable
that there would be any rules in place that would allow information being kept
from the public. There are a number of ways to trade on the stock market today.
We do not all use brokers etc. to make our trades. If the public does not have
access to all of the information available to make a wise investment decision,
that is tilting the table unfairly.
While some people may not use the information provided, if it isn't provided,
then a decision is already been taken out of your hands.
Sincerely,
Ad Dugan
Author: at Internet
Date: 04/27/2000 11:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Stop Selective Disclosure
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Proposed Regulation FD: File No. S7-31-99"
Norma S. Gross
Author: "WALTER HUNNEL" at Internet
Date: 04/27/2000 2:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S37-31-99
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Sirs,
If I am a shareholder, I should have access to current information being given
to any outsider, other current shareholders, or potential shareholders. If I do
not, the sharing of the information amounts to an attempt to manipulate the
market for the advantage of a few at the expence of the many. Insider trading
has been illegal for quite some time as it is a few, using information not
available to others, to create an advantage for themselves. I see no difference,
except for the number of people involved, between the current practice of
providing "selected analysts" with information and classic "insider trading."
If I am a person looking to purchase stock in a company, I feel I deserve to buy
on accurate, current information, and at a price that reflects that information
- not at some price set by "Market Makers" with information not available to the
general public.
I support legislation or rules to increase the availability of information, and
do not support any legislation or rules that codifies the status quo or a
reduction on openness required.
Thank you.
Walt Hunnel
Lawrence Memorial Hospital
Systems Administrator
785 840-2957
Pager # 830-5329
Author: "Buddy and Jean Hutchinson" at Internet
Date: 04/27/2000 12:49 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Full disclosure
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I am a private investor that considers research to the key to my past and
future investment success. Advise I have followed through on, on paper, has
been 85 to 90% ineffective.
Simply, I strongly support FULL DISCLOSURE to the investors and public, so
we can make our own decisions with out analyses input, Those who want the
analysis input can still utilize it based on their still forthcoming
comments.
Thank you for your attention to this information.
Buddy Hutchinson
Author: Kenneth Luoto at Internet
Date: 04/27/2000 5:20 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed RegulationFD: File No.S-7-31-99
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As a stock market investor, I implore you to change regulation noted
above to include disclosure of information to all interested individuals
rather than just the selected Wall Street analysts as has been
customary.
Respectfully yours,
Kenneth Luoto
Author: at Internet
Date: 04/27/2000 3:14 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. 57-31-99
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Please level the playing field
William C Maag
407 Virgo
Mission, Tx
Author: "swani mc Grath" at Internet
Date: 04/27/2000 11:19 AM
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TO: RULE-COMMENTS at 03SEC
Subject: SEC Full Discloure Rules
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We must have full disclosure rules. I urge you to adopt them.
Allen K. McGrath, Jr. M.D.
ADOPT FULL DISCLOSURE
Author: at Internet
Date: 04/27/2000 10:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File no. S7-31-93
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I have previously written to support full disclosure, but, after hearing
a spokesperson for the SIA this morning on National Public Radio, I wish to
comment again. The SIA spokesperson said, in essence, that if a public
corporation were to be required to make public to all what it makes public to
analysts alone or, at least, to analysts first, they would stop disclosing any
information other that that required by law or administrative regulation.
His stated belief was that these publicly traded companies would be fearful
that what they might say publicly might be information that "could move the
market." Fearful of allegations of market manipulation, they would, upon
advice of counsel, not say anything, not even to the analysts which would be
detrimental to all investors on the presumption that universal non-release of
information is bad for all investors. Somehow he failed to acknowledge the
converse, that universal information release is good for all investors.
Were publicly traded companies to remain mum, at least we individual
investors and professional analysts would be on the same level playing field.
The spokesperson for the IS, however, opined that information from publicly
traded companies needs to be released privately to a select few, professional
analysts, who can make sense of this information and wisely inform investors,
presumably their clients. These may be the same professional analysts who had
at least three day's advance notice that Abercrombie & Fitch was going to
announce an earnings disappointment and, perish the thought, advised their
clients to sell before everyone else found out.
If the thoughtful, insightful analyses of these professional analysts add
value to the information made available to all, then analysts will be
rewarded in the marketplace. The marketplace rewards added value. As it
stands, one cannot separate how much value is added by their thoughtful
analyses and how much value is added, to a select few, by their advance and
possibly insider information. Promulgate an even playing field policy. Let
all information be released to all simultaneously. If analysts' analyses add
value to information released to all, then they will be rewarded and this
policy will not harm them. It will, however, help us individual investors
who eschew the expensive opinions of professional analysts and full-service
brokers in favor of acting on our own research and informed opinions. I urge
you to grant us full, simultaneous access to information that is now, often,
released to a privileged few. Promulgate a full disclosure policy.
George W. Morrison
1075 N Hills Blvd, Suite 360
Reno, NV, 89506
Author: "rjreid" at Internet
Date: 04/27/2000 5:21 PM
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TO: RULE-COMMENTS at 03SEC
Subject: change to rules
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Dear Sir,
One can understand why Wall street analists want preferential treatment
with regard to information. It is so they can be the first to buy when the news
is good and the first to sell when the news is bad. This is tantamount to
entrenching coruption in the financial services industry. It may be equated with
insider trading. I don't think this is beneficial to the industry and will lead
to distrust and unending litigation.
Sincearly, Robert J. Reid
Author: Robert Sarao at Internet
Date: 04/27/2000 4:37 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Let us hear....
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To whom it may concern:
I am opposed to the unfair rule of selective disclosure... As an
independent investor I feel that I should be able to get any news
concerning a company that anyone else gets. Without it, it is more or less
discrimination on grounds of income, more or less... The large
institutional investors get the upper hand already by being able to sway
markets with with large portfolios... PLEASE KEEP SELECTIVE DISCLOSURE OUT
OF THE STOCK MARKETS.... Thank you...
Robert P. Sarao
* * * * * * * * * * * * * * * * * * * * * * * *
From the desk of:
Robert P. Sarao
26 Ramgren Road
Lunenburg, MA. 01462
Email: sarao@tiac.net
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Author: at Internet
Date: 04/27/2000 8:16 PM
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TO: RULE-COMMENTS at 03SEC
Subject: (no subject)
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" Proposed Reg. FD: File no. S7-331-99 "
Let everyone know the correct facts about companies. It's the only fair way.
Martha Staley
Author: "Ken & Rachel Staples" at Internet
Date: 04/27/2000 10:39 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7=31-99"
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Proposed regulation should be open to everyone, not just a select few. We need a
level playing field. Perhaps I would start investing if I had an equal chance
instead to the analysts getting first shot to make the big bucks first.
Ken Staples at kenrach@cybrquest.com
Author: "norm tucker" at Internet
Date: 04/27/2000 1:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. St-31-99
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We want this proposed regulation passed into law!!!
Norm Tucker
Author: Veronica Valenti at Internet
Date: 04/27/2000 8:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Public Disclosure Rules
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Please provide ruling requiring public companies to simultaneously make
available all financial disclosures so that ALL investors have access to
the same information at the same time.
Thank you.
Veronica C. Valenti
Author: at Internet
Date: 04/27/2000 6:55 PM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Full Disclosure
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Count me as another VOTER who will remember and speak out if
this playing field is not leveled.
Ron Young
rdyoung@hotmail.com
Author: "Zaczkowski; Dan" at Internet
Date: 04/27/2000 1:33 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Selective disclosure
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I am an investor against selective disclosure.
Dan Zaczkowski
http://www.sec.gov/rules/0427b02.htm