Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Mary Akers at Internet
Date: 04/27/2000 3:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear People at the SEC,
Please do 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.
Mary Akers
Mary Akers
ww1013@worldweb.net
Author: "Anderson; Gary" at Internet
Date: 04/27/2000 5:17 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Individual investors have every right to know all public information about
the companies they own at the same time as any other investor--including
institutions and analysts! The system is far too heavily stacked in favor
of insiders.
Gary Anderson
Author: Suzanne Bange at Internet
Date: 04/27/2000 4:34 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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..Please do the right thing for the small investor... Wall Street's
policies have helped only big institutions in the past. Please put the
power where it belongs, with the people. This is, after all, a
democracy. Promote fairness in investing. There's only one moral,
ethical choice to make. Please make that choice.
Bart Bange
average investor
Author: david f bartholomew at Internet
Date: 04/27/2000 3:58 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am opposed to selective reporting by companies. They have already
enough ways to obscure the relevant facts about managements actions and
self rewards, as well as the health of the companies. It is completely
wrong to allow companies to altogether withold information that may
impact other people's descisions, financial resources, and even jobs. If
anything, SEC regulations should demand even better disclosure with the
bad news and questionable actions prominently reported.
One thing that I have learned over the years is that companies (and
management in particular) lie a lot! What's more, after working closely
with many members of management. I learned that they pride themselves on
making fools of other people and taking tremendous advantage of them.
Please do not relax the reporting requirements of public companies.
David Bartholomew
1236 Assumption Dr
St. Louis, MO 63125
Author: Andy Baumer at Internet
Date: 04/27/2000 3:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I believe the proposed regulation will benefit individual investors as
well as improve the overall efficiency of the market. Many investors
will continue to rely on member analysts of the SIA, but with the speed
of distribution of information using the internet, those investors which
seek the information will find it available immediately. The SIA's
comments requesting denial of the proposed regulation show that they are
only concerned with continuing their advantageous position. It is
unbelievable that the SIA suggests that continuation of the existing
system will "contribute to ... less volatility" given recent market
swings. The proposed rule should be implemented as the immediate
dispersal of information will result in a more efficient market.
Andy Baumer
648 Adell Ave
Idaho Falls, ID 83402
Author: at Internet
Date: 04/27/2000 3:33 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No S7-31-99
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Selective Disclosure is clearly morally wrong and unfair. Please end this
ridiculous practice that benefits only the wealthiest and least vulnerable.
An individual's dollar is just as much money as Corporate America's and much
harder to come by.
Peggy Berry
Author: at Internet
Date: 04/27/2000 1:55 PM
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TO: RULE-COMMENTS at 03SEC
CC: Chad_Byersdorfer@cargill.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern:
As I read the reaction that the Securities Industry Association had
to the above stated proposed rule, I was shocked and insulted. As a
personal investor, I believe that I am as qualified to make decisions
concerning my personal finances better than anyone, due to the fact
that I have my best interests at heart. If I may quote from their
statement,
"It hardly needs saying that analysts perform a necessary and very
valuable function in the U.S. capital market. They, together with the
media, are the principal way in which important financially significant
information (including information contained in prospectuses and
reports filed with the Commission) effectively reaches most investors
and gets reflected in the marketplace. The alternative model of
millions of individual investors and potential investors poring over
prospectuses and periodic reports is highly theoretical and out of sync
with the real world."
Am I to believe that the SIA thinks that I am so ignorant that I
cannot disseminate the 10-Q statements that are available free on the
internet? Can I not tell when someone is telling me a lie? They are
telling me that I cannot ferret out information from companies on my
own behalf?
The SIA speaks of "individual knee-jerk reactions to specific
information". In my mind the SIA is the one with a collectively large
knee-jerk reaction to the proposed rule. Why should they as analysists
being the only ones privy to important information before the actual
owners/stockholders of a company are informed? This rule is a long
time in coming and definitely not "will undermine the great advantages
of the current system" as the SIA states. I would urge the SEC to
adopt this rule for the benefit of all individual investors.
Sincerely
Chad Byersdorfer
Author: at Internet
Date: 04/27/2000 4:59 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Re: Proposed Regulation FD: File No. S7-31-99
I applaud the Commission for reviewing rules and regulations written 65 years
ago and considering changes more adaptable to the Imformation Age.
I support full disclosure and free flow of corporate business and financial
information to ALL members of our society in a simultaneous and timely manner
so we may make our own informed investment decisions.
In this modern era of mass communications and intellegent investors, it makes
no sense to perpetuate the limited flow of information to "insiders" and a
selected elite few who may withhold or put their own biased spin on the
information for whatever reasons.
Elton W. Chase
2416 Wedgewood Dr. SE
Olympia, WA 98501
E-mail: eltonchase@msn.com
Author: "JD Chong" at Internet
Date: 04/27/2000 10:56 AM
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TO: RULE-COMMENTS at 03SEC
CC: at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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I support your adoption of this proposed rule to make the playing field
level for all who invest in America. Everyone should have the same
information to invest or divest in a company, and it should be made
available all at the same time.
J
JD CHONG
2100 3RD AVE APT 1605
SEATTLE WA 98121-2303
Author: Edward Clutter at Internet
Date: 04/27/2000 4:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: File Number S7-31-99
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I am an individual investor. All news should be made available as fully
and as completely as possible to all interested parties at the same time --
that includes us individual investors as well as the big Wall-Street firms.
I am quite capable of making my own decisions, without the help of
Wall-Street and I should not be put at a disadvantage just because I choose
to go it alone. By the same token, information available to them should
also be made available to me, so that my decisions, right or wrong, are
base on all the current knowledge, not just a selected part. And I should
not have to expect to pay for information that is not proprietary. Pass the
regulation.
Edward Clutter
1060 Northbrook Drive
Aiken, SC 29805
ph 803 649-7087
Thanks
Author: Don Dansby at Internet
Date: 04/27/2000 2:24 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am for equal disclosure of company information to ALL investors. Early
disclosure to large investors should be illegal. That is the same as
insiders trading on un-disclosed information.
Don Dansby
2600 Lemmontree Lane
Plano, TX 75074
Author: "Dave and Suzanne Delgado" at Internet
Date: 04/27/2000 9:12 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Being an individual investor, I highly commend the SEC for your proposal to
allow us to have the same timely access to information that the selective few
receive. It is high time the selective disclosure granted solely to analysts
comes to an end. I hope the new proposal, if passed, will level the playing
field and allow everyone to invest with the same timely information.
Thanks for the good work.
Sincerely,
David L. Delgado
Author: "Lynn Divoll" at Internet
Date: 04/27/2000 2:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Many years ago the elite in the computer world assumed the general public
wouldn't be able to effectively use "their" device and took no steps that
would relinquish their hold. Then along came an individual who determined
that was not the case, developed the software that allowed the general
public access and the rest is history. Open the disclosure of information,
deemed important enough to disclose to select individuals and organizations,
to the general public. Surprisingly we might again be able to put it to
good use.
Lynn Divoll
New Investor
Author: Matthew Faust at Internet
Date: 04/27/2000 3:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Proposed Regulation FD: File No. S7-31-99
I'm for it.
Matthew Faust
Author: at Internet
Date: 04/27/2000 3:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regualation FD: S7-31-99
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I am amazed that this legislation has even been proposed. I, and my compete
are AGAINST it.
Jerome O. Fitzmaurice, President
jofitzmaurice & co
1840 Sequoia Avenue - Ste. 110
Burlingame, CA 94010-5353
Phone/Fax: 650-697-7695
e-mail: jofitz60@aol.com
Author: "Ford; Keith" at Internet
Date: 04/27/2000 1:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Briefly, I would like to express my support for your proposed rule
prohibiting selective disclosure and expressing my outrage that it was ever
permitted. I
If I am to have confidence in the market, I should not have to worry that
someone else has access to information while I do not at the same time as
the company claims it is disclosing the information.
thank you.
Keith Ford
Author: Neal Goman at Internet
Date: 04/27/2000 1:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs,
I have been watching, listening, and reading the debate regarding FD. I
am sure you have received many eloquent responses regarding the pros and
cons of this proposal but I feel I need to express my views.
I am an individual investor and a member of an investment club in
Minneapolis, MN. I regard myself as a long term buy and hold investor. I
resent the SIA's contention that I, with my "knee-jerk reactions to
specific information", am the reason for market volatility. I seem to
remember that the market downturn of Oct. 1998 was attributed to the
institutional investors while the small investors held the course and
didn't lose confidence in market. The number of mutual funds that have a
turnover in excess of 100% contribute more to market volatility than any
small investor.
SIA believes that companies do not provide, in their SEC required
filings, complete information needed to make investment decisions. It is
only tenacious ferreting in face-to-face meetings by a few analysts that
will bring this information into the marketplace. If this is true then
let's amend the filing requirements (not something I think is needed,
but that may be a future debate).
SIA believes that it is the competition between independent analysts
that allows for the possibility of complete disclosure. It is their
desire to get the most information to their clients and beating the
completion to the punch that drives the analysts. In the real world,
analysts are not independent. They work for brokerage firms. Firms with
large financial interests in doing business with the companies being
favorably reviewed. Firms with large financial interests in getting
investments to change hands. If anyone is to be objective about
information in the market it is more likely to be the independent media
than employees of a brokerage house.
SIA believes that efficiencies can only be accomplished when a few are
privy to information of interest to the entire market. This is insider
trading as far as I am concerned. It allows one segment of the market to
have an advantage and that does not make for an efficient market.
Sincerely,
Neal Goman
Author: "FGurwin" at Internet
Date: 04/27/2000 4:08 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No. S7-31-99
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Those of us that own stocks have the right to know the same news that
analysts get early on. Oftentimes, the analysts work for stock brokerage
firms that seem to make money on knowing news before anyone else. How easy
it is to have their clients sell or buy before the analyst makes his
"educated" comments which have such important effects on the market. I have
watched analysts make those remarks and then seen the market react on it.
Let's even the playing field and give the important information to those of
us who have an interest in the market, too. A few should not have an edge
over the rest of us.
If there is something important to tell us---then tell us ALL! Talk about
insider trading! WOW!
Florence Gurwin
Author: Jim Healy at Internet
Date: 04/27/2000 10:59 AM
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TO: RULE-COMMENTS at 03SEC
CC: "'tmfmax@aol.com'" at Internet
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Gentlemen:
I would submit that individual investors need and deserve equal access to
information along with the Wall Street stock touts/manipulators
("Analysts").
In a world where 95+% of the companies followed by Analysts have a "buy" or
better rating, do you really think that Wall Street is a credible source of
information for investors, as they claim to be? Most companies are
downgraded (to a buy, accumulate or hold, never a sell) only after mangement
issues earnings warnings, discloses fraud, etc. Which Analysts are those
who are ferreting out this information beforehand? Which would have the
courage to disclose such information given the resulting loss of
underwriting and advisory fees for their institution and hit to their own
pocketbook?
The sole reason that Wall Street opposes the equality of information is so
that Analysts would no longer be able to alert their large institutional
clients about material information gleaned in a closed-access call or
meeting, before the public has access to the same information. This current
imbalance of information is antithetical to the principle of a fair
marketplace and enables institutions to trade and profit on material
information which is not available to the investing public.
Please pass the proposed regulation and restore some fairness to the market.
Best regards,
Jim Healy
Author: charles hollabaugh at Internet
Date: 04/27/2000 1:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I believe that the proposed regulation is in the best
interest of the investor and should be approved. The
investor not the analyst is the one who must make the
choice for his investment. The more information the
investor has the better HE or SHE can make that choice.
Author: "Aubre D. Howell" at Internet
Date: 04/27/2000 3:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom It May Concern.
I am writing to express support for the proposal to require that publicly
traded corporations fairly disclose to all interested parties any material
information.
Equal disclosure strengthens investor-friendly status between individuals
and securities analysts/institutional managers.
Tank you Aubre Howell
Author: "Humphries; Nancy " at Internet
Date: 04/27/2000 4:01 PM
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TO: RULE-COMMENTS at 03SEC
Subject: FW: File No. S7-31-99 -- Regulation FD
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> BellSouth Corporation has carefully read and considered the Commission's
> Regulation FD proposal. We are mindful of the Commission's concerns
> regarding selective disclosure but respectfully disagree with the approach
> enbodied in the proposed Regulation.
>
> Companies subject to the Regulation would be significantly adversely
> impacted in their compliance efforts
>
> While the "materiality" of some corporate disclosures is apparent (e.g.,
> earnings for an upcoming period to fall 5% below consensus estimates),
> most information imparted in the course of communications with analysts
> does not fall within clear-cut lines of materiality. Companies
> continually disclose bits of information to analysts so they can construct
> their models and advise their clients as to expected company performance.
> This information may be immaterial in isolation but material in
> combination or within the context of the analyst's conclusions.
> Furthermore, information considered immaterial by a corporate official
> when disclosed may prove to be material by subsequent market reaction.
> But even that indication may not be clear, as factors affecting stock
> price movement are difficult to establish with certainty. As a result,
> companies' compliance with Regulation FD will of necessity be tested and
> validated in hindsight.
>
> Unlike prospectus or Form 10-K disclosures that can be carefully
> considered and crafted by corporate officials, accountants, and counsel,
> informal disclosures that would be subject to Regulation FD are often
> impromptu and given in question and answer sessions, telephone conference
> calls, one-on-one meetings and other unstructured sessions. It would be
> unduly difficult, burdensome, and costly for corporate Legal Departments,
> Investor Relations Departments, and Public Relations Departments to
> monitor communications with all third parties sufficiently to ensure
> compliance with the proposed Regulation.
>
> Liability to companies deemed non-compliant could be severe
>
> It would be very difficult for companies to defend themselves in SEC
> enforcement cases where stock price movement implied material information
> was "selectively" disclosed, regardless of the reasonable judgment of
> company officials prior to disclosure.
>
> Companies that were deemed to have failed to file a required Form 8-K
> presumably would lose their Form S-3 eligibility, a severe penalty
> considering a potentially inadvertent mistake of judgment as to
> materiality. Of more concern, companies in registration could face civil
> damages or rescission claims from investors from material omissions if a
> required Form 8-K was not filed.
>
> Under the proposed Regulation, persons outside the direct control of the
> company ("agents") could impart liability to the company through their
> disclosures. Significant transactions in which BellSouth has been
> involved recently have been leaked to the media prior to consummation and
> disclosure through normal press releases. These leaks may have come from
> investment bankers or other agents of the company. Regulation FD
> disclosure should not be mandated nor should liability attach to the
> company from such third party disclosures.
>
> The public interest would not be served by Regulation FD
>
> The two most likely impacts of Regulation FD would be that companies
> sharply curtail their communications with analysts or sharply increase
> their public disclosures through press releases and Form 8-K filings.
> Analysts are a critical channel for corporate information, and their
> analytical and interpretive overlay add perhaps even more value to the
> market than the disclosure of raw data by corporations. Curtailed
> disclosure would be a disservice to the market, but this is a realistic
> possible reaction to the proposed Regulation.
>
> Over-disclosure is the other most likely reaction. Companies concerned
> that after-the-fact market reaction may indicate that material information
> was selectively released may overreact by issuing press releases and
> filing Form 8-K reports in such volume that the prominence of truly
> material disclosures is lessened.
>
> Regulation FD does not create exceptions for many needed transactions
>
> A number of questions are presented by the proposal. How do companies in
> registration resolve the duty to disclose under Regulation FD while they
> are in the "quiet period"? Can issuers disclose material non-public
> information to buyers of their securities in private placements without
> making a general public announcement or filing? How can information be
> shared with potential investors in roadshows without triggering a general
> disclosure obligation?
>
> The presumed benefits of Regulation FD do not justify the detriments
>
> We do not believe that selective disclosure is either epidemic or a
> growing phenomenon. We note that recent studies by organizations such as
> National Investor Relations Institute indicate that more and more
> companies are holding conference calls that are open to members of the
> media and individual investors. Companies are now web-casting analysts
> meetings over the Internet. Organizations such as NIRI are urging
> companies to open their disclosure practices and they are doing so.
> Chairman Levitt's campaign against selective disclosure is influencing
> corporate practice. Given the anecdotal and empirical evidence that these
> initiatives are effective, we do not believe that Commission regulation is
> either warranted or would accelerate the evolving disclosure practices.
>
> For these reasons, we strongly urge the Commission not to promulgate
> Regulation FD.
>
> Respectfully submitted,
>
> Nancy C. Humphries
> Vice President, Investor Relations
Author: "Rahul Joshi" at Internet
Date: 04/27/2000 8:40 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hi,
I am against the selective disclosure sought out by Wall Street.
Rahul
Author: "Philip R. Kohls" at Internet
Date: 04/27/2000 1:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No.S7-31-99
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To: Securities and Exchange Commission:
Please end this rule of partial disclosure. Company information that
is meant for the public should be given to all at the same time. How to
interpret that information will be determined by the brokers' skills and
investor savvy. Earlier access to information has nothing to do with
ability, just positioning for a head start arbitrarily denied
independent investors.
Yours,
Philip R. Kohls, PharmD
Author: Henri Lajer at Internet
Date: 04/27/2000 1:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation fd: file#s7-31-99"
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Dear Sir
I would like to made my voice heard concerning this above proposed
legislation. I believe that it is vital that all companies must be made
to give out important information to Wall Street analysts simultaneously
to the public at large.
HENRI LAJER
Technicolor employee.
North Hollywood, CA.
Author: at Internet
Date: 04/27/2000 2:05 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To: SEC
RE: Proposed Regulation FD: File No. S7-31-99
To Whom it May Concern,
The general investing public has every right to know the facts about any
company they are investing in at the same time as Industry Analysts. To
state otherwise is to take a position protecting the "insider" system that
has existed in the past.
Respectful submitted,
Edward A. Loseman
Self Employed
Author: "john mac donald" at Internet
Date: 04/27/2000 4:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Selective disclosure is UNAMERICAN. What people do with the information is
what is important. Many individuals will continue to seek advice on items
they do not understand. I hope that the SEC will tear down the information
wall which divides the general public from selective financial insiders.
This will promote equal and simultaneous access to information for everyone.
Industry professionals have a built in advantage even when information is
available to everyone simulataneoulsy. These professionals are experts in
their field and can act in their clients interests as they newly optained
information becomes available. It is only fair that the individual investor
has the right to access and interepret information as quickly as an industry
professional.
Please stop selective disclosure. Make information available to all who
care to find it.
Sincerly,
John K Mac Donald Jr.
Author: Michael Mathews at Internet
Date: 04/27/2000 11:48 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom it May Concern:
I am writing to express support for the proposal to require that
publically traded corporations fairly disclose to all interested parties
any material information.
The United States can take pride in the fact that it has the best
regarded reporting standards in the modern world. Anyone who has read a
prospectus for a global or international mutual fund is familar with the
disclaimer that investments in foreign securities may entail greater
risk. To quote from the prospectus of the AIM Global Growth Fund:
"Foreign companies generally are subject to less stringent regulations,
including financial and accounting controls, than are U.S. companies. As
a result, there generally is less publicly available information about
foreign companies than about U.S. companies."
I see no reason that the United States should permit corporations to
selectively disclose material information to securities analysts or
instititutional managers prior to any other investors or potential
investors. In fact, I believe that equal disclosure further strengthens
our investor-friendly status.
My own investment portfolio includes a variety of instruments including
mutual funds, individual company stocks, stocks selected by screening
mechanisms, treasury bonds and cash equivalents. I have taken great
pains to educate myself about financial statements and investing risks
and strategies. I have read the prospectus of each mutual fund, and I
have read the 10-K and 10-Q reports of the individually selected
companies. I realize that we have a long way to go in educating our
citizenry about the benefits and risks of investing, but we have made
great strides in the past several years.
Requiring complete and fair disclosure of material information is
another step down the path of facilitating individual financial control
and the increased prosperity of our citizens.
Thank you for your consideration of this matter.
/s/ Michael Mathews
--
------------------------------------------------
| Michael Mathews michaelm@sanfranmail.com |
| San Francisco, CA |
------------------------------------------------
Author: "Steve McDonnold" at Internet
Date: 04/27/2000 12:03 PM
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TO: RULE-COMMENTS at 03SEC
Subject: YES on Proposed Regulation FD: File No. S7-31-99
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There is no reason why Wall Street analysts should receive preferential
disclosure of information from publicly-traded companies. In fact, this age-old
practice should be outlawed. Please pass Reg FD.
Author: Mark Menke at Internet
Date: 04/27/2000 11:57 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs,
I fully support the proposed rules concerning fair disclosure. To allow
a
select few early access to material information is not justified. Please
force companies to follow disclosure rules that would benefit the general
investing publice.
Thank you,
-Mark Menke
--------------------------
"There is an ancient Celtic axiom that says 'Good people drink good beer'.
Which is true, then as now. Just look around you in any public barroom and
you will quickly see. Bad people drink bad beer. Think about it." - Hunter
S. Thompson
Author: Barry Minai at Internet
Date: 04/27/2000 11:16 AM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed Regulation FD:File No.S7-31-99 (fwd)
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I am stongly in favor of full disclosure rule. It is the only way for the
public to have a fair and even playing field against the wall
street giants. Thank you.
Barry Minai
Author: Larry at Internet
Date: 04/27/2000 2:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Public disclosure should be -- PUBLIC. This is common sense. Disclosure
to analysts is not public disclosure. Analyst privileges are no
different from conspiracy via a trust. True, it's cheaper and easier for
many companies to use PR firms and circles of well-known analysts;
disseminating and defending information in the court of public opinion
is painful and difficult. But although analysts may offer a route that
is cheaper and easier, it's not a FAIR route. We can't blame companies
for using this route if it is encouraged by statute and policy; but
there is no reason to encourage such behavior.
Lawrence Morton
2816 Kensington Dr
Kalamazoo, MI 49008
Author: "George Moser" at Internet
Date: 04/27/2000 2:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Having read a number of opinions on this matter I can only conclude that the
advance release of market price sensitive information to selective interests
serves the cause of no one but those selective interests.
There is absolutely no compelling argument in support of selective
disclosure.
George Moser
Author: Jeffrey Mumford at Internet
Date: 04/27/2000 1:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I strongly support the rule (Proposed Regulation FD) requiring, 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.
Jeffrey Mumford
Author: "SHERL PERKINS" at Internet
Date: 04/27/2000 1:28 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File no S7-31-99
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Stop selective disclosure!
Mr. Sherl W. Perkins
Retired, Boeing Manager
Author: Eric Rasmussen at Internet
Date: 04/27/2000 2:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Ladies and Gentlemen,
I am writing to support the new proposed rules (Proposed Regulation FD: File
No. S7-31-99) to combat selective disclosure of information by public
companies.
I use online brokers to invest and would like the same access to financial
information that the analysts enjoy.
Sincerely,
-Eric
Eric Rasmussen
United States
National Sales Manager
Nikkkei Electronics Asia
Nikkei Business Publications
Ph# 415-902-4822
Fax# 408-327-1139
email: eric-nea@pacbell.net
Author: at Internet
Date: 04/27/2000 5:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD; file No.S7-31-99
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I believe the same information companies give to Wall Street analysts should
be given to prospective investors. Without this information the investor is
placed at a disadvantage,in my opinion. The analyst may give a " slanted "
evaluation because of a vested interest & place undue risk on the " street
investor ". Signed, Loren Roberts, Retired
& Investor seeking valid information to make an intelligent evaluation of a
given stock.
Author: at Internet
Date: 04/27/2000 4:01 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: FD: File NO S7-31-99
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STOP selective disclosure. It is biased and goes against everything our
economy is built on.
Tracey Roberts
Author: Robert Sarao at Internet
Date: 04/27/2000 4:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
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
Author: Dave Scott at Internet
Date: 04/27/2000 12:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: No. S7-31-99
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Help Stop Selective Disclosure, please. We all deserve a level playing
field. The SEC should do more to protect the small investor.
Dave Scott
Author: at Internet
Date: 04/27/2000 4:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe individual investors should have access to the same information as
brokers by mandating company information be released to the news media
instead of just 'leaked' to a select few. Thank
You.......................Carol Siris
Author: Lydia Sund at Internet
Date: 04/27/2000 3:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No. S7-31-99
------------------------------- Message Contents
Please move ahead with the new regulations!
Lydia Sund
Author: "Michael Tekel" at Internet
Date: 04/27/2000 3:54 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD, File No. S7-31-99
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I am most definitely in favor of SEC advocating a level playing field for all
investors by
making pertinent information available to the public, and not to analysts,
brokers, the so called"high rollers" who more often than not benefit from early
information.
Sincerely,
Michael G. Tekel
Author: "dsthomp" at Internet
Date: 04/27/2000 1:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Gentlemen, Let the public in on what the brokers get before us.
Many of us don't use anything except research and common sense guide us.
Give us a "Fair Shake", Please!
Thanks
Don S. Thompson
43 845 Portola Ave.
Palm Desert, Ca. 92260
760 568 9052
No affiliation with anyone.
Author: "Touzalin; Eric L; JR; CMFBP" at Internet
Date: 04/27/2000 4:10 PM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir or Madam,
Please put an end to this selective disclosure policy that is currently in
effect. Every investor has the right to know the facts as well as the Wall
Street analysts. Thank you.
Eric Touzalin
Author: craigweaver at Internet
Date: 04/27/2000 1:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I agree that information is becoming more available with technologies, but
as has always been the case, those with the most money (analysts, investment
companies, etc...), get the "best" information earlier than the stockholders
and the general public. This new regulation FD probably won't erase that
problem, but it will let people know where right and wrong is, and let them
factor in the consequences of their actions. Because they get away with it,
doesn't make it right.
I'm in support of Proposed Regulation FD: File No. S7-31-99.
Regards,
Craig Weaver
Micron Technology
Manufacturing Systems
Boise - Assembly
(208-368-4650)
craigweaver@micron.com
Author: Ray Wilber at Internet
Date: 04/27/2000 1:54 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No.S7-31-99
------------------------------- Message Contents
Dear Sirs:
It is in the best interest of all Americans for the SEC to ban selective
disclosure.To eradicate this tool of wall street and let all Americans know
what is transpiring within corporations is in the true tradition of George
Washington ,Thomas Jefferson and our other founding fathers.Let us as
individual investers,make our own decisions on the same facts as wall
street.It is our money and we have a right to know all the facts.No small
band or group should hold the advantage over the rest of the population
regarding financial,investment,or public company information
Thank You,
Ray Wilber
Author: Tom Wilson at Internet
Date: 04/27/2000 3:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the proposed Regulation FD by SEC.
Thomas Wilson
Savant Software, Inc.
Author: Annenberg at Internet
Date: 04/27/2000 10:55 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am a college student and I do not have the money to hire a full tiem
brokerage service. In addition, I enjoy doing my own reading and my own
research about companies and understanding how they are evaluated, and
how all the numbers work. I do not like being fed any information
without understanding where that information comes from. I agree that I
might not have the same level of information and it might take me a long
time to understand it all, but that's the point of learning and doing
things on your own. I disagree with the SIA because I do believe I am
intellegent enough to make my own decisions about the value of
securitites. If I make mistakes then I learn from them. I bet you full
brokerage firms have made tons of mistakes but they always cover them
up. I am not ignorant nor am I emotional when it comes to the stock
market. I am not foolish to gamble with my own money. Furthermore,
analysts do not make the market less volatile because they do not have
complete control over who buys and who sells.
If a company is public than so should its records, because this just may
lead to companies being able to hide more things in there numbers and
not have to disclose them to their investors. In the end, it is the
public's money that is buying up these shares, therefore, we have a
right to know about what we are buying into.
Jenny Yazedjian
Student at the University of Southern California
http://www.sec.gov/rules/0427b06.htm
