April 28, 2000
     
Mr. Jonathan Katz
Secretary
Securities and Exchange Commission
450 5th Street, NW
Washington, DC  20549-0609
     
Re: File No. S7-31-99 (Regulation FD)
     
Dear Mr. Katz:
     
I am writing in support of SEC's Regulation FD proposal.  As a newly public 
company, Net2000 Communications, Inc. has recently addressed the issues 
relating its dissemination of information to the financial community.  As 
the director of investor relations, my role within our organization is to 
provide this information to all elements of the financial community in the 
most effective manner.  As a member of both the Association for Investment 
Management and Research (AIMR) and the National Investor Relations Institute 
(NIRI), I believe the recommended disclosure guidelines by AIMR and NIRI are 
not only consistent, but also provide much-needed definition to one of the 
most important responsibilities of a public company.  I believe Regulation 
FD standardizes AIMR and NIRI guidelines and will ultimately lead to more 
and improved information being delivered to all investors.
     
As the Commission points out in the proposal, Regulation FD will require 
that when disclosure of material information takes place, it is done so 
publicly, and that if material information is non-intentionally disclosed, 
public disclosure will soon follow. There seem to be a few practical 
requirements imposed on the public company as a result of Regulation FD. 
That is, (1) including all investors when material information is disclosed 
to any investors, (2) not disclosing material news in situations where all 
investors do not have equal access to the information, and (3) if material 
information is inadvertently disclosed, prompt full public dissemination of 
those facts.  
     
I believe the practical implications to comply with these requirements are 
minimal, and are generally in place today by most public companies (or 
should be).  For example, Net2000 makes sure statements (press releases) are 
broadly disseminated and to all audiences simultaneously, and conference 
calls are open to members of the public.  Alternatively, if the company does 
have a forum which would make the dissemination of information to the public 
impossible (industry conferences, private meetings, or one-on-one phone 
conversations), then care needs to be taken that material non-public 
information is not disclosed in that forum.  These policies are not 
cumbersome or costly to adhere to, as there are several services that will 
make the audio from conference calls available to the general public over 
the Internet for no cost.  Also, it is not only prudent to fully disseminate 
material news to all members of the public, but it is also already a 
requirement of The Nasdaq Stock Market.
     
It seems to me there are two key issue of debate over Regulation FD.  First, 
are the risks of selectively disclosing information in discussions that 
companies necessarily have with professional analysts and the potential risk 
of shareholder litigation as a result of such selective disclosures.  And 
second, the risk that the response of public companies over these fears will 
be a reduction in the amount of information disclosed to all audiences.  I 
believe these  concerns, while sincere, are not as grave as some argue.  It 
is clear to me the benefits of communication with both professional 
investors and individual investors, enhanced shareholder value.  I do not 
think public companies will disregard the benefits of having a fully 
informed investor base over the small burdens necessary to comply with 
Regulation FD.
     
I would suggest, however, that increased guidance from the SEC on what 
constitutes "material" information would alleviate many of the Regulation FD 
concerns of public companies and investors who fear a reduction in 
information flow.  Further, with a clearly defined Regulation FD, I believe 
corporate IR professional and senior managers will have a bright line that 
they can use in rebuffing any investor who is looking for information that 
may be material.  Enhanced clarity on the kind of practices that are not 
restricted under Regulation FD will ensure the comfort of public companies 
to continue to provide the kind of information necessary to all investors. 
Such examples might include providing information to professional analysts 
who require very detailed information in creating their forecast models for 
the companies they follow, and other information that may be provided to any 
investor in phone conversations that would not be considered "material".
     
Thank you for the opportunity to comment on this important proposal.  I 
commend the SEC in its effort to provide enhanced information to all 
investors and in its judgement in looking to organizations such as AIMR and 
NIRI in forming these proposals.  Please feel free to contact me should you 
desire any further information.
     
     
     
Robert Bannon, CFA Director, Investor 
Relations Net2000 Communications
2180 Fox Mill Road
Herndon, VA  20171