Date:    12/19/1999  12:14 PM

Subject: Open Disclosure

Dear SEC,
        I applaud your Chairman Arthur Levitt's comments about Full public and
open disclosure.  Further, I absolutely support Proposed Regulation FD 
(Fair Disclosure) whcih would require that:
     
     (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.
     
        I am a individual investor, not a customer of any of the large
Wallstreet full service brokerages,  and I feel that selective 
disclosure is little more than disguised "insider information" that is 
used AGAINST ME since I don't subscribe to those services.
Corporate information should be free and available.
     
        Further, I would urge the SEC to investigate the "conflict of interest"
situation wherein companies with a financial and vested interest in a 
particular security will issue public advisories, such as BUY or HOLD on 
that same security.    Seems to me they're doing nothing more than 
hawking their own commodity, rather than providing an unbiased
analysis.  If companies can continue to issue analysis in stock they own 
or sell, then they should be required to disclose the extent of their 
interest in the security they are giving their analysis of.   I hope I've 
described that adequately to explain what I'm talking about.  It really 
does seem like a conflict of interest, or their analyses are being passed 
under false pretenses.  The public has no way of knowing if that analysis 
is based on corporate financials and performance or on the analyst's 
interests in selling their own shares of the security in question.
     
        Again, thank you for garnering public comment.
     
        John Hellmann
        1124 SW Leschi Drive    
        Oak Harbor, WA  98277