Sent: Monday, April 15, 2002 10:02 AM 
Subject: Pending Rule Changes & A New One (s7-08-02) 

Sir:  Regarding the release of quarterly and annual 
financial results, I have no good reason for seeing this 
changed.  Accuracy is the objective and meeting reporting 
deadlines is often a scramble, thus leaving the lengthier 
periods but requiring a much higher degree of 'absolute' 
accuracy is the more desirable goal. 
 
The reporting of insider transactions in a more timely 
manner is a must.  The technology is here to allow reporting 
within 48 to 72 hours of a transaction, so why allow any 
longer for corporate insiders to report trades? 
 
Foreign Corporations.  Using fineline legal means, domestic 
corporations find it advantageous to incorporate or re-
incorporate offshore.  Often the main reason is to avoid 
'full taxation' or avoid certain liabilities.  So choosing 
this route should define them as foreign corporations, and 
thus defined, Tyco International's trading symbol should 
become TYCF, and Stanley Works, SWKF.  The result is that 
they are no longer 'American' companies and their selection 
in certain portfolio types is prohibited, e.g., a domestic 
equity mutual fund could no longer hold these.  Then 
companies would have to weigh costs of being patriotic 
(truly domestic) vs unpatriotic (offshore).  The SEC should 
be able to instigate such a rule. 
 
Sincerely, 
Robert M. Flora 
28 Stacy Drive 
Belle Mead, NJ 08502