Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Michel Arcand at Internet
Date: 04/27/2000 8:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I beleive everyone should have access to this information.
Michel Arcand
Author: "Steven Arena" at Internet
Date: 04/27/2000 10:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Level the playing field, do not allow institutions and analysts inside
information before the general public knows.
Author: "ddb" at Internet
Date: 04/27/2000 7:08 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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April 27, 2000
2545 W 69th Court
Anchorage, Alaska 99502
907-243-6743
Securities Exchange Commission
re: Proposed Regulation FD: File No. S7-31-99
Dear Sirs:
I commend the SEC for proposing the above rule. I strongly support this rule. I
believe communication should be open to the public. We the public should have
equal access to information from companies. I do not trust the judgment of
brokerage firms more than I trust my own judgment when it comes to the market.
However, for those who wish to enlist the interpretation of a broker, they
certainly are free to do so. The rule does not prevent them from doing so.
I believe that the SIA's comments regarding this rule are very much biased
towards their own self interests. Even if their comments are well intended, they
certainly suffer from a conflict of interest which should disqualify them as
being "mandatory interpreters" for us the general public. I can appreciate the
SIA's desire to keep this rule from becoming a realty. It so clearly and
obviously takes away their power in one aspect of the market. It must be
difficult for the brokerage firms to adjust to the fact that the public is now
beginning to take more interest and control in their own financial affairs. The
public is beginning to understand the market and the fact that a brokerage firm
is not going to take more steps to protect their money than they in fact are
willing to take.
This rule will not have an adverse affect on the market, but will in fact
increase fairness and a respect for Wall Street. The SEC has made much progress
in bringing democracy and fair play to the market. I fully support the SEC in
making and implementing this rule. I have confidence that you will do so.
Thank you,
Dwight Becker
I am a Program Coordinator for the State of Alaska, Division of Senior Services.
I am an investor and trader.
Author: "HULALULU" at Internet
Date: 04/27/2000 4:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
BRAD BLANCK
UNITED STATES POSTAL SERVICE
AMERICA SHOULD HAVE FAIRNESS AND FREEDOM OF INFORMATION FOR ALL!!!
HULALULU@HULALULU.COM
ROLLING STONES COLLECTIBLES
HTTP://WWW.HULALULU.COM
Author: Richard Chin at Internet
Date: 04/27/2000 9:01 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD: File No. S7-31-99
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I absolutely support outlawing selective disclosures 100%
Richard Chin
325 Wawona St.
San Francisco CA94127
Author: Ralph Colby at Internet
Date: 04/27/2000 7:31 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Eliminating selective disclosure will injure the few who currently
benefit from it and benefit the many who do not. Full speed ahead!
Ralph Colby
Cool, CA
Author: "John L. ( Jay ) Colvin; Jr." 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 HELL YES TO
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STOP IT , STOP IT, STOP IT, NOW..... stop rule Proposed Regulation FD: File No.
S7-31-99
John L. Colvin, Jr. La. self employed.
Look at last feb. '98 when BellSouth selectively disclosed to their inbred
buddies on Wall St about missing their upcoming quarters. Then 24 hours later
revealed it to the public. in the 24 hours prior to the public announcement the
Wall Steeters sold off & tanked BLS stock price. The general public was screwed
& bitch slapped by BLS & Wall St. Please SEC PLEASE help me & all the joe
averages of the world. Please do this 1 thing. MM manipulation is bad enough on
the Nasdaq, but slective disclosure is out right insider buying & selling on
insider info.
Author: LOMITA-LOUNGER@webtv.net (James Craig) at Internet
Date: 04/27/2000 6:44 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Help level the playing field, stop selective disclosure !
James Craig
Author: "Patricia Deldon" at Internet
Date: 04/27/2000 6:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proprosed regulation fd file no s7-31-99
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Patricia Del Don
I too am a small investor, and don't understand how one may justify giving the
breaks to the large investor that probably doesn't need as much. Please give
equal opportunity to all.
Author: at Internet
Date: 04/27/2000 11:22 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Full and Fair Disclosure is extremely important to the individual investor.
Approve the Changes, Please.
Brian Drexler
Crystal Lake, IL
Author: at Internet
Date: 04/27/2000 10:37 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs,
I support the proposed regulation FD. I am concerned with the current
practice where select individuals or institutions have advance notice of
important information concerning companies I own. This leads to an unfair
advantage gained by these other co-owners or non-owners of the company. I
believe I have at a minimum, the right to equal access to the information
about a company I own as someone who has no ownership interest in the
company. I also question why someone with an account at specific brokerages
should receive recommendation to buy or sell a stock based on information
that is not available to all investors. Proposed Regulation FD will be a
large step forward towards a more fair equities market for all investors.
Thank you for your time.
Timothy DuFrene
Author: at Internet
Date: 04/27/2000 10:45 PM
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TO: RULE-COMMENTS at 03SEC
Subject: FD File No. S7-31-99
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Please pass this rule. It's about time that "secret" information is given to
a select few. The little guy needs help.
Thanks.
Ron Favor
RonFavor@aol.com
Author: at Internet
Date: 04/27/2000 12:08 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Prop. Reg: S7-31-99
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The proposed regulation should be supported. It is needed to provide
timely information to all
investors rather than favoring a select few.
Lawrence N. Fuchs
Albany NY 12203
Author: at Internet
Date: 04/27/2000 10:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
In the spirit of sharing, I humbly submit the following for your consideration,
my fellow Fools.
Dear Sirs:
I submit this posting in support of proposed Regulation FD.
Let us suppose for a moment that the following four statements, generally the
basis of the comments by the SIA opposing promulgation of Regulation FD, are
true in all respects.
1. Analysts perform a necessary and valuable function in the U.S. capital
markets.
2. 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.
3. Analysts make the markets less volatile.
4. Analysts spend much of their time ferreting out negative information about
companies.
I respectfully submit that any conclusion drawn from these four statements
that purports to establish that analysts need better information or more timely
information or more private information than other participants in the market --
i.e., conscientious individual investors spending their own money to become
owners of companies -- is unsupportable and quite probably incorrect.
In its comments to the SEC, the SIA notes "We believe in the maximum flow of
information from issuers, whether directly or through securities analysts and
the media, to the marketplace." I suspect there is universal agreement on this
overreaching philosophical position. The SIA then quotes the SEC's own
materials, "... the federal securities laws do not generally require an issuer
to make public disclosure of all important corporate developments when they
occur. ... [I]n the absence of a specific duty to disclose, the federal
securities laws do not require an issuer to publicly disclose all material
events as soon as they occur." It then goes on to note that the SEC proposes
changing this long standing policy to ".subject an issuer to a general
obligation to make public disclosure of any material fact that it discloses to
any person outside the issuer ."
Hear, hear!! I believe that is exactly what is proposed, the crux of the
debate. Can anyone, other than those with a vested economic interest in
maintaining the status quo, possibly make the case that rules developed and
promulgated 65 years ago -- in 1935, for Pete's sake -- to regulate what has
become a very different securities industry should not be critically reevaluated
and quite probably amended or modified?
Everyone agrees that information is the basis on which objective, critical
decisions about investments should be made. What is the advantage in restricting
its availability? To have analysts, bankers, brokers, and lawyers protect us
from ourselves? Who can realistically contend -- much less prove -- that making
information more available will lead to poorer investment decisions? Who can
support the position that corporate executives have an obligation to speak to
representative of some of its owners -- analysts employed by investment banks
and brokerage houses -- and not to the much broader group of its owners --
individual holders of equity stakes? The only potential problem, of course, is
if executives are -- as suggested by the SIA -- using private sessions with
analysts to spin the facts or shade the truth with a wink or grin or nod or
gesture to protect their companies or their personal positions. If that's the
case, exposure to a broader base of people with a range of knowledge and
perspectives would be revealing and embarrassing.
I cannot recall a comment in support of this proposed regulation that suggests
that communication by company executives be curtailed. No one wants to eliminate
the role of analysts, who provide a potentially valuable service to a large
segment of the investment community. No one wants to put analysts out of work or
close down their companies. What a growing number of conscientious, intelligent
investors suggest is that everyone should be given the access to the same
information at the same time. Broad access to accurate information, as proposed
in regulation FD, is the most equitable way to provide all investors, big and
small, individual and institutional, the opportunity to make informed investment
decisions -- decisions about how they spend their money -- in the most timely
manner.
Regards.
Trying very hard to be informed and, therefore, smarter.
David Hasson
Cincinnati, OH
Author: "Bill Henning" at Internet
Date: 04/27/2000 8:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please put a stop to selective disclosure.
Maike K Henning
Author: "KDH" at Internet
Date: 04/27/2000 9:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Sirs,
Please stop the practice of selective disclosure. This is quite harmful to
the individual investor. Discontinuation of this practice will help level
the playing field.
Yours Truly,
Kevin D. Hinshaw, MD
2821 North Ballas Road, Suite 240
St. Louis, MO 63131
314-432-6137
e-mail
Author: John Holcomb at Internet
Date: 04/27/2000 9:10 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Total equity is only to be found in full and total , across the board
disclosure of all pertinent facts to all concerned at the same time.
If you want control, then level the playing field, and the risk, by
having all have the same information at the same time, No exceptions.
JOhn Holcomb
Author: "Mike Ilczyszyn" at Internet
Date: 04/27/2000 9:34 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Just to let my voice be heard, of course the public should get the information
simultaneously with analysts. What reason could there be not to other than
profit? Level the playing field I say.
Mike Ilczyszyn
Author: at Internet
Date: 04/27/2000 9:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Selective disclosure contributes to the wide disparity of resources the
institutional investors bring to bear to disadvantage the individual
investors. It should be stopped!
- Brian Jacoby
Author: at Internet
Date: 04/27/2000 11:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD: FILE NO. S7-31-99
------------------------------- Message Contents
DO NOT KEEP US IN SLAVERY ANY LONGER WITH ANCIENT RULES AND LAWS. VOTE TO
GIVE US THE INFORMATION WE DESERVE FROM THE COMPANIES WE INVEST IN.
REMEMBER-------WE MAY NOT ELECT YOU, THE SEC, BUT WE DO ELECT THOSE WHO CHOOSE
YOU. YOU AND YOUR ACTIONS ARE BEING WATCHED BY THE AMERICAN PEOPLE. NOW THAT
WE HAVE WORLD-WIDE COMMUNICATIONS , WE WILL BE DECIDING ISSUES THAT THE
POWERFUL HAD NO IDEA WE WOULD EVER BE CAPABLE OF KNOWING ABOUT.
SIGNED, J. GLYNN JEANSONNE, UNIV. OF TEXAS HEALTH CENTER
Author: "Colleen M. Kelly" at Internet
Date: 04/27/2000 9:26 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am in favor of full disclosure.
Colleen M. Kelly
Author: laugibbins at Internet
Date: 04/27/2000 9:34 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As a struggling middle-class tax-paying and voting professional and
private investor, I OPPOSE Selective Disclosure.
Full disclosure is the foundation of our free markets. Public access to
information allow individual citizens like me to make informed choices
and participate in the American dream.
Selective disclosure gives companies (aka the big boys) license to
collude - very anti-competitive!
My name is Renee Lau. I am an American citizen, a resident of the state
of California.
Encourage full and free disclosure.
Renee Lau
1976 Creek Road
Livermore, Ca 94550
925-449-5848
email: rcljag@pacbell.net
Author: Doug Levin at Internet
Date: 04/27/2000 9:53 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Rule Committee:
This letter is to comment on certain aspects of the proposed
regulations; specifically those dealing with disclosures of non-public
information by company management.
I have not read the text of the proposal (which deals primarily with
how such disclosures may or may not be deemed insider trading) but if
my outside reading on the subject is correct, the SEC proposes to
require full public disclosure of all information provided to market
analysts by company management.
Apparently, under current regulations market analysts have access to
information provided by management not available to the general
public. The purpose of which is to allow them to develop opinions on
companies that they can share with their clients.
As a licensed Certified Public Accountant with Deloitte & Touche LLP,
I am in a position to know inside information about my public clients
which I have derived from my discussions with company management. The
SEC regulations and my own profession's code of conduct require that I
not act on or reveal such information to other parties. In addition,
I am prohibited from any direct or indirect financial investment in
those companies.
What strikes me is the similarity between a CPA's relationship with a
public company and an analyst's. CPA's are expected to examine a
company's financial statements, make inquiries of company management,
and issue an opinion on the fairness of the financial statement
presentation. A market analyst is expected to examine company
financial statements, make inquiries of company management, and then
issue their opinion on the company as an investment (albeit their
access to financial data is either limited or delayed).
Therefore, like a CPA, there should be a strong code of conduct for
such analysts that demands they:
- Not act on their information, either for themselves or their
family, employers, or other affiliates;
- Reveal their opinions in a consistent fashion so that all members
of the public can have access to it simultaneously;
- Be required to act in a manner similar a CPA's with respect to
insider company information;
- Have systems of internal controls that watch over and regulate
their investments and actions with respect to these rules.
If such a code exists, and the SEC has tested and is comfortable that
it is working appropriately to protect the investing public, then I
would be comfortable with the existing system.
However, certain issues with respect to the markets lead me to
conclude otherwise. They are:
- Brokerages, which are the most likely to retain market analysts,
are also often in the business of making markets on the NASDAQ system
in the same stocks they report on. To use a phrase from my own code of
professional conduct, this at least provides "the appearance of
impropriety".
- As far as I know there is no market analyst profession which
regulates membership and establishes its own code of conduct.
Further, company management is not required to speak to only such
"certified" market analysts, increasing the possibility that
management comments could be misused or inappropriately obtained.
- The democratization of the public markets has been a tremendously
positive factor in their improvement as well as that of the nation's
economy. Making public all conversations between management and
market analysts appears to be a continuation of this trend that
should also have a strong positive influence.
- Finally, this would greatly simplify the SEC's burden of
protecting the investing public. Instead of developing and enforcing
a complex, difficult to police code of conduct with respect to
nonpublic information provided by management, the proposed regulation
would instead provide that such information would be public
immediately. This would effectively even the playing field and allow
all investors equal access to the facts.
Based on these considerations, I respectfully request that you
consider these issues and allow the proposed regulation to take
effect.
Thank you very much,
Douglas K. Levin, CPA
Author: "turnin2" at Internet
Date: 04/27/2000 9:18 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
Please make the system fair. End selective disclosure.
Thank You.
Michael McMullin
Turnin2@gateway.net
Author: at Internet
Date: 04/27/2000 10:20 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
As a high-net worth individual investor I believe it is wrong that I have
access to more investment information than my less prosperous co-investors.
Be fair - stop selective disclosure.
The first statement on your web-ste from Charles Schwab legal council
accurately reflects my personal viewpoint.
Nathan Miller
Scottsdale, Arizona
Author: "Wayne" at Internet
Date: 04/27/2000 8:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD File No. S7-31-99
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Date: 4/21/00
Subject: Proposed Regulation FD File No. S7-31-99
Several years ago I had my life savings and my company's money in cd's and
money market accounts
doing basically nothing. I therefore decided to try the stock market. With
no experience in this area I chose to transfer my money to one of the well
known brockerage houses.
Well 5 years later, after a lot of commissions paid, small returns and much
needed experience gained I have decided to do my own investing.
I would like to see that all investors big or small have the same
information available.
Thank you
Wayne Morley
President
Industrial Services & Design, Inc.
Author: "Gary Nelson" at Internet
Date: 04/27/2000 8:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
I submit this posting in support of proposed Regulation FD.
Let us suppose for a moment that the following four statements, generally
the basis of the comments by the SIA opposing promulgation of Regulation FD,
are true in all respects.
1. Analysts perform a necessary and valuable function in the U.S. capital
markets.
2. 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.
3. Analysts make the markets less volatile.
4. Analysts spend much of their time ferreting out negative information
about companies.
I respectfully submit that any conclusion drawn from these four statements
that purports to establish that analysts need better information or more
timely information or more private information than other participants in
the market -- i.e., conscientious individual investors spending their own
money to become owners of companies -- is unsupportable and quite probably
incorrect.
In its comments to the SEC, the SIA notes "We believe in the maximum flow of
information from issuers, whether directly or through securities analysts
and the media, to the marketplace." I suspect there is universal agreement
on this overreaching philosophical position. The SIA then quotes the SEC's
own materials, "... the federal securities laws do not generally require an
issuer to make public disclosure of all important corporate developments
when they occur. ... [I]n the absence of a specific duty to disclose, the
federal securities laws do not require an issuer to publicly disclose all
material events as soon as they occur." It then goes on to note that the SEC
proposes changing this long standing policy to ".subject an issuer to a
general obligation to make public disclosure of any material fact that it
discloses to any person outside the issuer ."
Hear, hear!! I believe that is exactly what is proposed, the crux of the
debate. Can anyone, other than those with a vested economic interest in
maintaining the status quo, possibly make the case that rules developed and
promulgated 65 years ago -- in 1935, for Pete's sake -- to regulate what has
become a very different securities industry should not be critically
reevaluated and quite probably amended or modified?
Everyone agrees that information is the basis on which objective, critical
decisions about investments should be made. What is the advantage in
restricting its availability? To have analysts, bankers, brokers, and
lawyers protect us from ourselves? Who can realistically contend -- much
less prove -- that making information more available will lead to poorer
investment decisions? Who can support the position that corporate executives
have an obligation to speak to representative of some of its owners --
analysts employed by investment banks and brokerage houses -- and not to the
much broader group of its owners -- individual holders of equity stakes? The
only potential problem, of course, is if executives are -- as suggested by
the SIA -- using private sessions with analysts to spin the facts or shade
the truth with a wink or grin or nod or gesture to protect their companies
or their personal positions. If that's the case, exposure to a broader base
of people with a range of knowledge and perspectives would be revealing and
embarrassing.
I cannot recall a comment in support of this proposed regulation that
suggests that communication by company executives be curtailed. No one wants
to eliminate the role of analysts, who provide a potentially valuable
service to a large segment of the investment community. No one wants to put
analysts out of work or close down their companies. What a growing number of
conscientious, intelligent investors suggest is that everyone should be
given the access to the same information at the same time. Broad access to
accurate information, as proposed in regulation FD, is the most equitable
way to provide all investors, big and small, individual and institutional,
the opportunity to make informed investment decisions -- decisions about how
they spend their money -- in the most timely manner.
Regards
Gary Nelson
Author: "Harvey Oakley Sr." at Internet
Date: 04/27/2000 7:00 PM
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TO: RULE-COMMENTS at 03SEC
Subject: FD:File # S7-31-99
------------------------------- Message Contents
I am not in favor of companys only giving important information to Wall Street
analysts. Without simultaneously giging that same information to the public at
large. regulation FD:File # S7-31-99 if passed will only serve to injure the
remaining confidance the public has in the government.
Harvey Oakley Sr.
Shadez Inc.
Author: at Internet
Date: 04/27/2000 10:12 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe that this rule should be implemented. All information from and
about public companies should be available to everyone at the same time.
There should be no privileged class "in the know." Anyone who gets
information that has not been publicly announced should be considered
insiders and be restricted to the activities of any insider, whether they are
corporate officials, wall street analysts or big investors. Protect the
public from the brokers and analysts.
Richard Oppenheimer
Naperville, IL
Author: "kumara prathipati" at Internet
Date: 04/27/2000 8:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I like level playing field.
Kumara S Prathipati
4992 hidden dune court
san diego
CA, 92130
619 261 3453
Author: William Prothro at Internet
Date: 04/27/2000 9:01 PM
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TO: RULE-COMMENTS at 03SEC
Subject: S7-31-99
------------------------------- Message Contents
I want to make it known that I am against selective disclosure. Please
end this. I am an individual investor and would like to have the same
information at the same time as the analysts.
Thanks and regards,
William Prothro
Author: at Internet
Date: 04/27/2000 10:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
All investors are equally entitled to know what's going on!!
Marlene Richter
Wild Hill Preserve.
Author: at Internet
Date: 04/27/2000 11:17 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Jay Ross
Rosewoods Custom Woodworking
Why do they get the golden goose?
Author: "Philip Semanchuk" at Internet
Date: 04/27/2000 9:13 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As a private investor, I hope you'll put an end to selective disclosure.
Equal justice for all, eh?
Philip
URL du jour: http://www.tvfa.org/
Author: Biren Shah at Internet
Date: 04/27/2000 9:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I support changing the rules to level the playing field. Analysts and
individual investors such as myself should be made aware of material
information simultaneously. This a no brainer.
Biren Shah
Author: "KATHRYN A SHIREY" at Internet
Date: 04/27/2000 9:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As an individual investor, I believe I have the right to the same
disclosures as Brokerage firms, and analysts. I am employed at a large
publicly held organization (NVLS) in which I hold stock. I believe that the
stock markets and investors will all benefit from full disclosure of
financial information from publicly held corporations.
Kathy Shirey
kathy.shirey@prodigy.net
Author: "Victor R. Smith" at Internet
Date: 04/27/2000 9:15 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Sirs:
I am writing in favor of passage of proposed regulation FD (Fair Disclosure)
which would eliminate the practice of selective disclosure of information
and require public disclosure of material information by publicly traded
companies. I think it is only reasonable to provide the individual investor
with the same information available to larger investment houses.
Thank you for your consideration.
Sincerely,
Victor R. Smith, M.D.
9908 Pebbleknoll Drive
Cincinnati, OH 45252
513 385-3452
Author: Theresa Smith at Internet
Date: 04/27/2000 10:13 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Excuse me!!! No, public companies should not be able to keep their
financial information private... secret from their investors, sharing
only with Brokers so that the brokers can use the upper hand to keep
their jobs.
Investor,
Theresa B. Smith
Author: stephen h stalker at Internet
Date: 04/27/2000 9:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed reg FD: fILE # s7-31-99
------------------------------- Message Contents
STRONGLY IN FAVOR! Public is aware of what has been going on and is
looking for some action to correct the situation! Those who oppose
positive change will be branded as crooks and/or sellouts weather it is
true in all cases or not!
Author: Chris Steinmann at Internet
Date: 04/27/2000 11:01 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Mr. Levitt,
As an individual investor, I am writing to say that I strongly support
the
implementation of Proposed Regulation FD.
I am very concerned with the fact that companies are presently willing
and
able to disclose information to selected analysts prior to the same
information being made available to the general public. I have read some
of the comments by individuals and groups against Proposed Regulation FD,
and have to say that I am highly offended by some of the ideas they put forth.
I feel that if corporate information is provided to any individual or
group, AT ANY TIME, then it should be provided to ALL individuals and
groups, at the same time. Based on the fact that there are often large
swings in stock prices during periods prior to corporate information being
made public, and more specifically, immediately before a comment by an
analyst, I have to wonder if the analysts are not making sure that their
primary clients are given advance notice of information. Such notice would
allow for stock positions to be adjusted, to the detriment of individual
investors. Is this fair, or the way that stock markets should be affected,
I do not believe so.
I read with great interest, and have to say that I strongly agree with
many of the comments provided by Ian Capps, President, PR Newswire
Association, Inc. in support of further tightening the rules proposed by
Regulation FD. If companies are allowed any leeway in providing
information to selected groups, prior to providing the same information to
the general public, the purpose of Regulation FD will be defeated.
I believe that the concept that companies will be less willing to
provide
information under these regulations to be without merit. Companies that
choose to withhold timely information from the public will find their stock
prices penalized as a result. However, those companies that build a
reputation of providing timely information, both "the good" and "the bad,"
will find that they are rewarded in the long run for their honesty.
In conclusion, I just wish to reiterate that I strongly support proposed
Regulation FD, because I feel that I, as an individual small investor, have
just as much right to timely corporate information as a market analyst
earning a seven or eight figure salary.
Please move forward with the implementation of Proposed Regulation FD as
soon as feasible.
Sincerely,
Christopher Ross Steinmann
Author: "Pamela St. Peter" at Internet
Date: 04/27/2000 6:27 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To whom this may concern:
As an individual investor, I too have been agitated by
the system under which companies up to now disclose
important information. I am please to learn of this
SEC regulation. Fair Disclosure is a good start.
It is my understanding that under the proposed
regulation FD:
"(1) whenever an issuer intentionally discloses
material information, it does so through public
disclosure, not through selective disclosure; and
(2) whenever an issuer learns that it has made a
non-intentional material selective disclosure, the
issuer make prompt public disclosure of that
information.
Under the proposal, a company could make the public
disclosure through one of several methods: (1) filing
the information with the SEC; (2) issuing a press
release; or (3) providing public access (for example,
by phone access or over the Internet) to the
conference call or meeting."
Thank you SEC Chairman Arthur Levitt, for really
bringing disclosure in the stock market arena into the
20th century. It seems in so many other areas of our
lives we are afforded full disclosure that you are so
correct in saying "the basic principle of fairness
deserves no less." Investing today is a means of
"saving" or investing in our futures, we are as
individuals investing in our retirements. I am like
so many others in todays work force that have no 401K
or retirement plan offered by employers. Savings and
sound investing IS my future. Should we not be giving
the adequate information to do so soundly?
Thank you,
Pamela St.Peter
=====
~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*
"Think you can, think you can't -
either way you're right!"
My webpage http://pstpeter.home.mindspring.com/
~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*~*
Author: "Frank Suttell" at Internet
Date: 04/27/2000 7:03 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The SEC is considering a rule that would require full disclosure to the public
and not just selectively and limited distribution. I am in favor to full public
disclosure of information. I understand how selective could and would provide
an advantage to financial companies the would put the little guy at risk.
Please make the playing field level.
Thank
Frank Suttell
Author: "PATKIDS4" at Internet
Date: 04/27/2000 9:58 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I have been monitoring and investing in the market since I was 16 years old.
I'm 43 years old now. I have always out performed the market.If there was a
total free flow of information I feel I could make an even better decision than
I already do.
Patrick Taitt
Author: at Internet
Date: 04/27/2000 11:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Analysts should be paid for their analysis, not their insider access to
information that is not available to the general public. Unfortunately unless
the SEC makes a rule requiring equal access to information, small companies
that need analyst coverage will be over a barrel. Unless they provide
nonpublic information, they risk not being covered, being unknown and being
required to pay a higher price when they need money from the capital markets.
There is also the subtle threat (probably never explicitly voiced) that if
the company does not provide this nonpublic information, the coverage will
not be as favorable. But if providing material nonpublic information to
analysts ahead of the general public were illegal, then the small company
could refuse.
This kind of fair disclosure rule cannot be made by market participants--only
government can make this step. The big insiders only want to protect their
entrenched edge and they will be ruthless and vehement in fighting to protect
their edge.
Transparency is essential to the efficient functioning of the markets. Equal
access to information means that individual investors do not have to assume
more risk than the insiders. Thus the price they can pay for a security will
go up, thereby increasing overall demand for the security and lowering the
price companies pay for capital. This will enhance our country and economy.
The internet technology which makes it possible to give individual investors
the same kind of real time information can greatly enhance the efficient
functioning of the capital markets. Cronyism and subtle blackmail must not
be allowed to interfere with what is best for our economy and country as a
whole.
Judith Thompson
2 Second Place
Brooklyn, NY
Author: at Internet
Date: 04/27/2000 10:27 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents
I believe that companies should be required to give important information to
the public at large as well as Wall Street analysts. Providing this
information provides investors with new information in a timely manner and
without interpretation and editing by analysts. If the investor desires to
consider the opinions of the analysts, he can still do so. However, there is
no substitute for the original unedited information.
Frncis T. Thompson, Ph.D.
Author: at Internet
Date: 04/27/2000 9:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe the SEC should strongly endorse changing the law to require that
all information made available to analysts become published on the internet
simultaneously. This is the only fair way to regulate information access.
Signed:
John H. Warner
Author: "Dale Zabel" at Internet
Date: 04/27/2000 10:36 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation F D: File No. s7-31-99"
------------------------------- Message Contents
Dear Sir: As an individual investor I want an even playing field regarding the
information that is given out by all companies. It is not in the best interest
of the Capitalistic system to have information regarding public companies
financial reports dispersed in two different ways.
Sincerely
Dale Zabel
Author: Jon Zyzyck at Internet
Date: 04/27/2000 9:58 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I'm against Selective Disclosure!
Thanks,
Jon Zyzyck
http://www.sec.gov/rules/0427b08.htm
