Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Arthur Curtin-Savard at Internet
Date: 04/28/2000 8:42 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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No to selective disclosure!
Gregory A. Abell
Author: mike altis at Internet
Date: 04/28/2000 10:38 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Dear SEC Official,
An efficient market requires that no group including Wall Street should have
an advantage in receiving significant news of publicly held companies over the
general public. Please level the playing field. Thank you for your
consideration.
Sincerely,
Michael Altis
President
Quality Assurance Consulting
Author: "Terisa Anaya" at Internet
Date: 04/29/2000 10:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Dear Sir/Ma'am,
I want to recieve the same information the professional analyst community
receives at the exact same time they receive it. Simultaneous! I see the
current system as nothing but a legal form of insider trading. It keeps the
"poor", individual investor at an extreme disadvantage. Why should the big and
powerful get the advantage? THIS IS A DEMOCRACY!!
WE SHOULD ALL HAVE ACCESS TO THE SAME INFORMATION AT THE SAME TIME.
Teresa Anaya
Registered Voter and Former IT Account Executive, Current Mommy
Flower Mound, TX 75028
Author: Michael Anderson at Internet
Date: 04/28/2000 9:34 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:
This is a rule change that is long overdue. The existence of an
information hierarchy that gives securities analysts privileged access to
information about publicly traded companies is inconsistent with both a
free market and a democratic society. Continuing to allow such access only
perpetuates distrust of analysts, brokerages, and markets in general. For
the good of the industry, adopt the rule.
Mike Anderson
2911 Hedgewyck
San Antonio TX 78217
Author: Sam Broderick at Internet
Date: 04/28/2000 5:14 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support public disclosure and vehemently oppose corporate
information being giving to selected Wall Street analyst. My vote in
November will also reflect this.
Sincerely
Sam Broderick
Author: Brandon Brylawski at Internet
Date: 04/28/2000 10:53 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir or Madam,
I would like to state my unequivocal support to ending the selective
disclosure
system under which companies can give information to some analysts while
keeping
it from the public at large. I believe that the investment community and the
economy
suffer when such deals are made, and that the current rules enrich a few at
the
expense of the many.
Good luck,
Brandon Brylawski
I am a private investor and not affiliated with any financial institution,
broker, or
investment advisor.
Author: "Eric Burleyson" at Internet
Date: 04/28/2000 10:26 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:
As one of the "small guys" -- an individual investor making his own informed
investment decisions -- I see *no* good reason for "selective disclosure" to
exist. *All* information should be available to *all* investors *all* the
time. I fully support the proposed "Full Disclosure" rule.
Eric Burleyson
Yellow Spring, WV
Author: "DAVID CAMBRIDGE" at Internet
Date: 04/28/2000 11:57 AM
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Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern,
I am writing you regarding Proposed Regulation FD. I am very supportive of this
proposal, in particular the language barring "Selective Disclosure". I have
many times as an individual investor found it very frustrating when a stock that
I own moves very rapidly up or down and there is no news to be found anywhere.
Inevitably a few days later a news release comes out which is responsible for
the rapid price change. I do not know for certain that these situations are a
result of selective disclosure of information to analysts prior to the actual
news release. That is the frustrating part of the equation, I don't know if it
is happening or if it isn't.
This situation has happened to me a couple of times on a stock which I own and
follow very closely, Hyperion Solutions (HYSL). On December 8, 1998, the stock
took a sudden drop in price 6 5/8 approximately 21% of its market cap on 10
times it's average volume. There was a rumor posted on a Yahoo message board
that upper management had met with analysts at an industry trade show and warned
them that the current quarter would be
soft.(http://messages.yahoo.com/bbs?action=m&board=4688103&tid=hysl&sid=4688103&
mid=1013.
There were news stories which mentioned the rumor, but no official confirmation
from the company.
http://messages.yahoo.com/bbs?action=m&board=4688103&tid=hysl&sid=4688103&mid=10
31
Many investors including myself shrugged off the rumors because of the company's
conservative past and a belief that the shareholders would be informed if there
were any material concerns about the quarterly earnings.
http://messages.yahoo.com/bbs?action=m&board=4688103&tid=hysl&sid=4688103&mid=10
34
There were mixed messages from the Analyst community, some said the quarter
would be soft, some said it would be fine.
http://messages.yahoo.com/bbs?action=m&board=4688103&tid=hysl&sid=4688103&mid=10
47
I wrote to investor relations about the rumors and this was the response I got.
"The drop in the stock price is attributed to market rumors that the company was
being sold and that due to an accounting irregularity, we would have to restate
our financials. Both of these rumors are not true. The management team is
comfortable with the current EPS consensus of $.31"
The stock continued to drop and on January 5th, the company announced that
earnings would not meet expectations with the stock trading at $17.35.
My point in relating this story to you is to show that individual investors are
severely hurt by this type of activity. The Wall Street community wants you to
believe that it is better for them to get the information, analyze it and
disseminate that information to the general public. In this case, there were no
news releases, only one analyst changed their earnings forecast. In the mean
time the individual investor was left to wonder, what was really said in that
meeting, should I sell. Without having that information ourselves, we cannot
make investment decisions. The Wall Street analysts want us to come to them and
pay big commissions to their brokerages so that we can get this type of insider
information. An almost identical scenario was played out this quarter with
Hyperion Solutions. A rumor started that the company had warned Morgan Stanley
the their 3rd quarter was weak. The stock dropped significantly, but they made
their earnings forecast.
I strongly urge you to adopt this proposal so that individual investors will
have a level playing field.
Regards,
David Cambridge
5689 Commentry
Sterling Heights, MI 48314
Author: "Kendall M. Cox" at Internet
Date: 04/28/2000 10:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am an individual do-it-yourself long term buy and hold investor. I
am very thankful for the opportunities the modern era affords the
individual investor. However, the idea that some data should only be
reserved for the Wall Street "professionals" is ludicrous. Individual
investors have the same right to data about companies they own or are
considering purchasing as anyone else. And besides, what happens if
some renegade "professional" takes this elite data and posts it on a web
site?
Author: teeteringrock at Internet
Date: 04/28/2000 10:01 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am a 65 year old widow who has done my own investing
for the past 20 years; started making my own decisions the
moment I finally realized just what CHURNERS and CON artists
these so-called professional brokers and analysts really are
Today I could probably buy and sell most of them. And you
say we aren't BRIGHT enough to make our own calls???!!!
Then consider for just a moment this little jewel of wisdom:
IF these brilliant so-called professionals are so smart, WHY
IN THE HELL ARE THEY OUT THERE STILL HAWKING THEIR
WARES????!!
They should be in my boat; taking vacations to Hawaii, going on
fantastic cruises and the rest of the time, counting my MONEY.
Please stop insulting the individual investors intelligence. Seems
this is the main aim of our government, playing the Big Brother
role for all of us idiots. OH PLEEZZZ!!!!!
J. A. Cox
Author: Kristen Davis at Internet
Date: 04/28/2000 10:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File s7-31-99
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Dear Sirs:
It is only right that all who make investing decisions should be able to
access information relative to their decisionmaking at the same time.
Thank you for your consideration of free and equal access for all.
Thanks,
Kristen Davis
Vice-President
Foxhill Sports Management
also: Women's Investment Club of Rock Hill (SC)
Author: "Jeff Diemer" at Internet
Date: 04/28/2000 11:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please disclose information to both investors and analysts alike so everyone
can make informed decisions regarding their investments.
Jeff Diemer
Author: "Alton Email" at Internet
Date: 04/28/2000 8:10 AM
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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 full support of your proposed regulation. It is time to let the
individual investor have equal access to corporate information.
Thank you for listening,
Gabriel Ferramola
Los Alamitos, CA
Author: "Patrick Gaughan" at Internet
Date: 04/28/2000 6:59 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 highly in favor of the proposed regulation forbidding selective
disclosure of important business information by publicly traded
companies.
The current SEC regulations regarding insider trading give
a very clear message -- use of insider information not publicly
known is illegal. Tipping other investors with such information
is illegal. It seems to me the current practice of selective disclosure
is nothing but legalized insider trading. If I were to somehow
discover the information being selectively disclosed and trade on
that information, would I be guilty of insider trading?
In any event, selective disclosure gives an unfair pricing advantage
to Wall Street analysts. By obtaining good and bad news before
the rest of the market, they are always at the head of the pack
whether the prices go up or down. This just isn't fair.
Patrick Gaughan, Individual Investor
Hillsboro, Oregon
Author: "W. G. Gehrke" at Internet
Date: 04/28/2000 9:23 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual invester with my retirement riding on my stock portfolio, I AM
100% FOR THIS REGULATION. It gives the small investor in Dallas, Texas
information we need to survive.
Wallace G Gehrke
wgehrke@flash.net
Author: Tom Giddings at Internet
Date: 04/28/2000 10:02 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Guess what? We are not stupid. We do not need protection from the
truth.
On the average we probably have as much, if not more, understanding of
the market as the analysts. Many of us have been at it for more years
than the analysts are old.
Give us a little credit and don't worry about our panicking when we find
out the truth.
We have a hard enough time getting the truth out of companies in
'uncomfortable' situations without having an intentional extra filter
placed between us and them.
Full disclosure to all is the only fair way.
It is the American way.
Author: Mark Harms at Internet
Date: 04/28/2000 9:47 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Madams and Sirs,
I support the regulation. Isn't the free flow of information one of the
key foundations upon which an open and democratic society is founded?
Mark Harms
PO Box 321
Spring Park, MN
55384
Author: Brad Hessel at Internet
Date: 04/28/2000 11:35 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am an active individual investor. Open conference calls are critical
to my decision making. Just this week, I actually asked a question at
one for the first time in my 25-year investing career. You guys are
right on target with this proposal -- it is incredible to me that this
manifestly unfair system of selective disclosure has persisted in clear
violation of the spirit, if not the letter, of insider trading law.
(Although I suspect that even if you did not put this regulation into
effect, the handwriting is on the wall with regard to this obsolete
exclusive practice, which the force of the market is likely to blow
away, anyhow.)
Anyhow, it's good to see my tax dollars at work so sensibly. Keep up the
good work!
Brad Hessel
Author: "Ronald Horkheimer; M.D." at Internet
Date: 04/28/2000 10:52 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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Friday April 28, 2000
Chairman Arthur Levitt, U.S. SEC
Last evening I had the pleasure of participating in your Investors Town
Meeting at Mount Mary College in Milwaukee, Wisconsin. I can't tell you how
simply delightful it was to have you come down from your Washington D.C.
Ivory Tower and meet with us person to person in our community. PLEASE
continue this program of personal contact with the individual investors of
this country.
I am writing today to ask you to support the simultaneous dissemination of
important company information to all citizens not just to the elite few Wall
Street analysts. PLEASE do all that you can to eliminate the current system
of selective disclosure.
Thank you.
Sincerely,
Ronald Horkheimer, M.D.
Author: "David Hoshour" at Internet
Date: 04/28/2000 11:45 AM
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Subject: Proposed Regulation FD: File No. S7-31-99
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I want to lend my support to the idea of making a level playing field for all
market participants. I think the brokerage industry is tremendously
self-serving in trying to protect its arrangement between analysts and companies
when it comes to having the first take on important information. This is not
protecting investors, it is protecting big brokerage firms.
I think it is insulting to investors and independent registered investment
advisors like myself to say that we need financial information interpreted for
us by analysts and that we are incapable of doing it ourselves. This is akin to
the medievel practice of the church murdering any heretic that dared to say that
the common people should read the bible for themselves. Only the priests' were
deemed qualified!
Well, I am far from impressed with big brokerage firm analysts - these high
priests of capitalism. They are, in fact, shills for the companies they pretend
to objectively analyze. Their game is kissing up to management for a chance to
do underwriting, not objective analysis. This is so obvious to anyone that has
worked in the industry that it scarely needs repeating. And their investment
savvy is the stuff of jokes around the water cooler at any retail brokerage
firm. Analysts jump off en masse after a stock has fallen and their typical
pattern on the way up is to issue buy recommendations only after a stock is up
and the good news is out. Analysts are useful to the investor mainly for their
descriptions of a company; as for investment advice on when to buy a company,
they are typically terrible.
These are hardly the people I need interpreting my financial information. I am
perfectly capable of interpreting company news on my own, thank you very much.
What I need is more information delivered in a more timely fashion, not more
late information filtered through an analyst. This is the spirit of progress in
our country and in our financial markets. I urge you to continue to strip the
brokerage firms of their private access to information.
David Hoshour
President
Cornerstone Investment Services
Author: "Loren C. Ipsen" at Internet
Date: 04/28/2000 9:01 AM
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Gentlemen:
I wish to comment regarding the proposed rule that would end the
practice of closed
analysts-only conferences or calls.
I believe that it is inherently unfair to make information available
only to a selected and
favored few. The individual investor should have an equal opportunity
to receive company
information and hear the company's response to questions posed by
analysts and others.
The SIA seems to feel that we are too dumb to interpret such information
and must have
it filtered for us by analysts. In the meantime, the firms who employ
the analysts are able
to make advance use of the information.
The proposed rule would tend to level the playing field. I urge your
favorable consideration
to adopting the rule.
Sincerely,
Loren C. Ipsen
1020 Main Street
Boise, ID 83702
Telephone: (208) 338-1001
Fax: (208) 338-8400
e-mail: lci@heiplaw.com
Author: "DEWEY & DALE ISGETT" at Internet
Date: 04/28/2000 12:06 PM
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Subject: PRPOPOSED REGULATION FD: FILE NO.S7-31-99
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I THINK EVERYONE SHOULD HAVE AN EQUAL PLAYING FIELD AND NO EARLIER RELEASES TO A
SELECT FEW.
I AM OPPOSED TO ANY RULES THAT DOESN'T MAKE IT EQUAL FOR EVERYONE AND NOT A
SELECT FEW.
DOROTHY S. ISGETT
BELLSOUTH TELECOMMUNICATIONS INC.
Author: "Landsman; Zeb" at Internet
Date: 04/28/2000 11:54 AM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I am an individual investor and by no means a so called "day-trader" writing
in support of the proposed regulation. I find the private disclosures to
analysts to run counter to nearly everything the SEC stands for. And I also
find analyst "recommendations" to be of no use.
Sincerely,
Zeb Landsman
Author: at Internet
Date: 04/28/2000 11:15 AM
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To whom it may concern,
I strongly support the leveling of the playing field between the
investing public and individual analysts, and therefore support the
changes in the regulations.
It is grossly unfair for some participants in the market to have access
to information not publicly available.
The argument that individual investors are unable or unwilling to do the
research required and need an analyst to tell them what to think is not
only fallacious, but is distinctly undemocratic. By a similar argument,
we could say that individual Americans are not smart enough to make
political choices on their own without it being filtered, not by
impartial political analysts, but by backers of the individual
participants.
The current state of affairs only undermines the confidence of investors
in the fairness of the market as a whole. Some players have inside
information. They can act ahead of time to enhance their gains or
defend against losses. If it is illegal for insiders to selectively
disclose to their friends about inside stock information, why isn't it
illegal for them to selectively disclose the very same information to
professional participants in the market? The SIA brief acknowledges
that information is being disclosed by these private contacts, at least
indirectly. That is, in fact, the point of the private contact!!
We will never know whether information is being directly passed because
the privacy of the meetings keeps the public and its watchdogs out.
This casts a pall of suspicion over the entire process, and therefore
the market in general.
This situation forces individual investors to invest with big mutual
funds whose analysts have access to information the individual investor
cannot get. Wouldn't you like to invest with a guy who might have
inside information? Fewer players in the market makes it more
predictable and more susceptible to undue influence and to
manipulation. It is only the large number of investors acting out on
their own initiative, on their own understanding of the company and its
place in the economy, that keeps the big guys from completely
controlling the market to their own advantage.
We have already seen, in the comments of certain analysts, especially
Mobius and Cohen, that their remarks carry a great deal of weight, so
much so that the technology sector has been thrown into turmoil by
them. I think it is highly likely that an investigation of these two
analysts and their trading activities would show that they acted ahead
of the general public and are buying back their sold shares now at lower
prices. A clear reason they have this power is because it is thought
that they have inside information and superior wisdom because of the
contacts they have. Reputations for being a great investor should not
depend on inside information.
I reject the SIA argument that the great mass of individuals cannot make
wise decisions if they have access to the same information that other
individuals have. In fact, an analyst, who has more at stake in the
billions of dollars s/he controls, is perhaps more likely to panic in
the face of bad news. S/he must act immediately, before others get wind
of the news, and this is likely to cause little thought and reflection
on the news before action. This is how bad decisions are made. Knowing
that all have the news at the same time means that all can decide
together what it means. Some of the time pressure for analysis may be
removed.
Inside information is wrong. No one should have it. No one. Level the
playing field and restore the confidence of the public in fairness of
the US markets.
Yours Sincerely,
Rev. Allan C. Lane
Author: "iraida1" at Internet
Date: 04/28/2000 11:11 AM
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actually I do not see it as an issue for debate, since the mid 50's the
outgrowth of the bill of rights etched in stone is equal access and equal
oppourtunity. Recent federal funding to the states and private organizations
also rubber stamps the issue concerning specifically information technology and
it's accessability to the general public. Look at recent goings on with
microsoft---hidden in the forest of issues is only one which all the issues are
bellied on---the possible control of the flow of information.
william lombardi
Author: Frank Lynch at Internet
Date: 04/28/2000 7:42 AM
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I support the regulation, and hope you will listen to the voice of the
public.
Francis P. Lynch, Ph.D.
Self employed and loving it!
Author: Deane Malaker at Internet
Date: 04/28/2000 8:59 AM
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Subject: S7-31-99 File Name: 34-42259.htm Regulation Full Disclo
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Using MSWord7.0
As a retired atty. and private investor I am upset and feel
disadvantaged over the fact that public companies can selectively reveal
company information to private parties. It is obvious that this
practice creates an unfair playing field for the private investor.
D. Malaker
Cleveland, Ohio
Author: Tom Marchbanks at Internet
Date: 04/28/2000 10:49 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Any 'company' information should be available to everyone NOT just a
select group of 'analysts'.
Tom Marchbanks
tmarchbanks@mindspring.com
Author: at Internet
Date: 04/28/2000 10:59 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Please level the playing field. Keep America the land for one and all.
Thanks for you time.
David C. Marott
Author: Sean McGee at Internet
Date: 04/28/2000 6:16 AM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs,
I can think of no justification for allowing the practice of
selective disclosure to continue. In a country that espouses the idea of
open, free markets, the current system is a vile holdover from the bad old
days of elitist capitalism. Selective disclosure benefits a few privileged
analysts and investors, at the expense of the vast majority of American
citizens. I urge you to end this egregious practice immediately. Put the
proposed regulation FD into effect, for the sake of all investors, not just
the privileged few.
Sean P. McGee * General Manager, Ohio Logistics Center
eVineyard, Inc. *
sean@evineyard.com * P: 614-876-8015
2192 Wilson Road * Columbus, Ohio 43228
Author: mmooney at Internet
Date: 04/28/2000 10:27 AM
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TO: RULE-COMMENTS at 03SEC
CC: m.mooney@mindspring.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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SEC,
I agree that you should not allow Wall Street to Oppose a Level Playing
Field. Disclosures should be public or not at all and in violation of
that principle should be subject in essence to "Insider trading"
statutes.
Follow your Public Service instinct and put the Regulation into
practice.
Michael Mooney
901-263-8750
FedEx TradeOne PhaseTwo
FedEx WTC Collierville
iXL-Memphis
901-473-2000
6750 Lenox Center Court, 3rd floor
Memphis, TN 38115
Author: "David Moore" at Internet
Date: 04/28/2000 9:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor, I wholeheartedly support the SEC's Fair
Disclosure proposal.
I look forward to having access to information traditionally only available
to analysts via private conference calls and presentations.
Individual investors such as myself should not have to "buy" access to this
private information by paying the exorbinate commission costs imposed by
these analyst's brokerage divisions, just to get access to their "research."
Thank you for your consideration of my comments.
David Moore
Philadelphia, PA
Author: "Jeffrey Nauman" at Internet
Date: 04/28/2000 10:16 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Regarding the proposed rule for Full Disclosure:
Knowledge is power, and hoarding of that knowledge by a select few limits my
ability to control my own decisions. In this new age of information
availability, it is ludicrous to allow firms to give information to a select
group (i.e., Wall street analysts), and not to the entire interest group
(i.e., all investors).
Wall street analysts are trying to "protect their turf", an understandable
move, but, "...the times, they are a changin'."
I my own industry, there are things happening which I would like to prevent.
But, in business, as in life, if one cannot adapt to change, then they will
become extinct. The dinosaurs would have loved to have slowed down the
global changes they faced, instead of adapting. But, alas, they "went the
way of the dinosaurs."
Give me the right to make my own decisions based on all the information, not
only information filtered through biased sources.
Thanks for proposing the new rule in the first place.
Jeffrey W Nauman
Author: Brent Pope at Internet
Date: 04/28/2000 11:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I would like to voice my support of this proposed change in the way
information is disclosed. The only question I have about it is, why didn't
someone do this earlier. As an individual investor, it is my opinion that I
not only have the right to receive information concurrent with "professional
analyst", but also I have the rational ability to digest such information
without reacting in such a way as to cause dangerous market volatility. I
believe other individual investors also have both this right and this
capability. Please approve this regulation. It's only fair.
Thank you.
Sincerely,
Brent Pope
Author: "Robert W. Pratt II" at Internet
Date: 04/28/2000 10:33 AM
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TO: RULE-COMMENTS at 03SEC
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Dear Sirs:
As an individual investor I would like to see information disclosed to
all...not just the big guys.. We deserve the same information. Informed
investors make efficient markets!
Robert W. Pratt II
Dallas, Texas
Author: at Internet
Date: 04/28/2000 6:52 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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All investors should have the same acess to the same information.
Eileen Proffit
Mohave Engineering and Assoc.
Author: "douglasr" at Internet
Date: 04/28/2000 11:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs:
As one of the burgeoning numbers of individual investors, I respectfully
request that you consider the discontinuation of selective dislosure regulation.
It is only fitting and right to do so in a democratic society.
Sincerely,
Douglas Rapier
Author: Faith Rendell at Internet
Date: 04/28/2000 8:35 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir/Madam:
Selective disclosure needs to stop. Analysts receiving company
information prior to other investors is unfair and should be made
illegal.
Now that information is available online and can be posted for
whomever wants to access it, the time has come to end selective
disclosure which works against the small investor.
It is important that company reports be available to all at the same
time. This is the very principle which supposedly guides our stock
market and which (unspokenly) assumes that all information is available
to all investors simultaneously.
I'm a small investor. Please make selective disclosure illegal.
Sincerely,
Faith Rendell
1565 Santa Clara St
Richmond, CA 94804
Author: "HardCopy Systems and Services" at Internet
Date: 04/28/2000 10:05 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I vote NO!
Keep prcedures the same as always.
Thanks,
Terry Roop, BellSouth.
Author: "Kathleen Schauer" at Internet
Date: 04/28/2000 10:49 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Selective Disclosure and Insider Trading File #S7-31-99
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I fully support the SEC proposal that public companies make full and immediate
disclosure of material events to the public as soon as they are learned. No
analyst intermediary is necessary to translate the meaning of such disclosure
before the belated release of the information to the public at large. I agree
with other such comments that I have read that analysts and their firms' large
and institutional investors have had an unfair advantage over the general public
for a long time. That is not to say that the production of meaningful research
based on insightful analysis by analysts and their brokerage and investment
banking house employers is not always appreciated, but this analysis should not
be unfairly based upon information not readily available to the public at large.
The availability of information has been made almost instantaneous with the
advent of the internet so the SEC disclosure proposal should not present undue
hardship to the public companies in expeditiously disseminating such
information. Many investors in the stock market these days are capable of and,
in fact, a significant number already do (myself among these individuals) make
their investment decisions by performing a good deal of their own research and
analysis before taking a buy or sell action on a security. Brokerage and
investment banking house research is only one source of information used by many
investors in deciding whether to invest in a company.
I think that implementation of these new rules will more importantly take a
large step towards making directors and managers of publicly owned and traded
companies more accountable for their actions or the lack thereof. After all, a
public company is owned by the public, only part of which is comprised of
institutional and large investors.
Thank you for the opportunity to comment on this proposed rule.
Kathleen A. Schauer
Financial Analyst, but commenting as a private citizen
Author: at Internet
Date: 04/28/2000 9:58 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Subject: Proposed Regulation FD
Dear SEC,
Thank you for moving toward a more democratic marketplace with the prospect
of required Fair Disclosure of material corporate information.
I strongly support Proposed Regulation FD.
Regards,
Darlene Schnatz
Beaumont, TX
Author: Bob Selim at Internet
Date: 04/28/2000 10:11 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear SEC:
The issue of selective disclosure is simple really, a matter of supply
and demand. Require all public corporations to release their public
information to the public, which according to me means everyone, at the
same time. If the public needs security analysts to make sense of it
(and, bless their hearts, to protect us from both corporations and
ourselves) then they can await the gratifying flood of demand for their
services.
If they don't hear from us, it just means we didn't call.
Sincerely,
Robert D. Selim
Author: Anand Shah at Internet
Date: 04/28/2000 10:36 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
It is my strong belief that equal dissemination of information can only promote
fair markets. Therefore, as indivual investor, I urge that this regulation be
put in place.
Thank you,
Anand Shah
Nxtwave Communications
One Summit Square
Langhorne, PA 19047
Tel: 267.757.1016
Fax: 267.757.1120
e-mail: anand@nxtwavecomm.com
--
Author: "John Stapleton" at Internet
Date: 04/28/2000 10:14 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD File No. S7-31-99
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Hello,
I am an investor in individual stocks for the long term. I do a fair
amount of due diligence before I purchase shares in a company.
I think it is only fair that any company executive who divulges
material information about their company, in an official forum of
analysts should be required to divulge that information to the
owners of the company - the shareholders - as well.
Thank you for registerign my opinion.
John Stapleton
CEO
Paskill & Stapleton Graphic Communications, Inc.
--
Paskill & Stapleton Graphic Communications, Inc
PS?Interactive
One Roberts Avenue
Glenside, PA 19038
tel # 215-572-7938
fax # 215-572-7937
When you're ready to be noticed.
Author: Charles Taylor at Internet
Date: 04/28/2000 11:07 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed
Regulation FD: File No. S7-31-99
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Selective disclosure should not be allowed.
Charles A. Taylor
Individual Investor
Author: "Scott Wheatley" at Internet
Date: 04/28/2000 8:19 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
I'd like to submit my support for this regulation. In applying common sense and
fairness, I don't see a GOOD line of reasoning for withholding pertinent
information for those of us investing for retirement, college, etc. I'd like to
see the raw data or hear a direct explanation, same as an analyst. Then I can
choose to listen to an analyst for additional interpretation, if I desire.
Please, remember, common sense and fairness. Many of us appreciate the freedom
to think for ourselves.
Sincerely,
Scott Wheatley
Author: Daniel Wright at Internet
Date: 04/28/2000 8:55 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please go through with the proposed rule change that levels the playing field
for all investors.
Thank you,
Daniel J. Wright
F5 Networks
Systems Consultant
d.wright@f5.com
(206) 607-0976
Author: John Wright at Internet
Date: 04/28/2000 8:33 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I'm in favor of the proposed legislation. It provides a policy towards more
open and accessible information which provides potential benefit to those
who deem to use it.
John A. C. Wright
Denver, CO
Author: "Zembruski; Henry Michael" at Internet
Date: 04/28/2000 11:12 AM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-31-99
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1536 Powers Avenue
East Meadow, NY 11554
April 28, 2000
Mr. Johathan G. Katz
Secretary
Security and Exchange Commission
450 5th Street
Washington, DC 20549
Dear Mr. Katz,
I am in favor of approval of the proposed regulation File Number S7-31-99
concerning selective disclosure and insider trading.
I believe in full, fair and simultaneous disclosure of material information
to everyone. The internet, cable TV, radio, personal computers and personal
devices (as the Palm) have opened the flow of information in the growing
communication and information technologies. We need modern regulations for
modern times.
I am not a powerful banker or broker or attorney or lobbyist.
I am a middle class college educated professional with a college educated
profession wife. I have one child in college and one in law school.
With regards to Regulation FD, I believe that all investors should have
access to issuers disclosure of material at the same time. A special class
of insiders should not have the privilege of selective disclosure and reap
the financial rewards to the detriment of the general public. I believe the
cost of filing Form 8-K or Form 6-K will not be a burden to the issuer.
With regards to Rule 10B5-1 and Rule 10B5-2, I favor the proposed
legislation as the rules on insider trading are clarified.
I hope the SEC is not swayed by the trade associations and lobbyists who
oppose the proposed regulations which will level the playing field for all
Americans and will hopefully eliminate some of abusive financial, political
and economic power of the "select few".
Sincerely,
Michael Zembruski
Mike Zembruski
(410) 993-2848
fax (410) 993-2807
email zembrhe@mail.northgrum.com
http://www.sec.gov/rules/0428b03.htm
