Date:    01/24/2000  5:29 AM


Subject: File No. S7-31-99

Wall Street loves selective disclosure.  With selective disclosure Wall 
Street can create its own form of insider trading.  The street can 
disseminate the information slowly to their friends - by cellular phone if 
necessary.  When a few key analysts are informed, they tell those near
them - their trading desk.  Their trading desk tells their friends on other 
trading desks. The analysts also tell key clients.  Who in turn tell those 
near them.   A few days before public announcement the news begins to appear 
in the market - stock and options.
     
The SEC has done everything they can to eliminate insider trading.  Yet so 
far they have tolerated the 'insider' trading which results from selective 
disclosure.
     
Even with immediate open disclosure, the public will still be at a 
disadvantage.  Most individual traders need to do something besides watch 
the market all day.  So even with immediate full disclosure, most will not 
receive the news until a few hours after publication.
     
But at least immediate full disclosure will eliminate the discriminatory 
process of selective disclosure.  Perhaps then the public will find ways to 
receive important information promptly via their broker or via personal 
digital assistants.
     
Vince Heying