Date:    03/22/2000  11:58 AM

Subject: Proposed Regulations on "Selective Disclosure"

To The SEC regarding proposed new regulations on selective disclosure:
     
As a member of the analyst community for the past six years, I have listened to 
hundreds of analyst conference calls sponsored by companies of all kinds.  I can
certainly appreciate the SEC's view that such calls can and do arbitrarily 
exclude large numbers of investors, particularly non-institutional ones.  I also
believe that analyst conference calls frequently do lead to the analyst 
community receiving certain kinds of information in advance of others.  
     
In the interest of a fair and open market, as well as the free dissemination of 
information, I suggest that all such conference calls be open to those who care 
to listen, but that only the analyst community - as defined by individual 
companies - be allowed to actively participate.  In so doing, the free flow of 
information would be maintained, and analysts would be allowed their usual 
access.  To open such calls to everyone, however, would lead to an extremely 
inefficient process, and would most likely result in most companies electing to 
drop the calls entirely.  The reason is that unsophisticated investors 
frequently ask pointless or non-specific questions which aren't relevant to the 
conference call.  (I know this because I have listened to several such calls 
when non-analysts somehow manage to participate.)
     
I appreciate that the SEC hopes to adopt new rules which provide open disclosure
between companies and investors, and I hope that the proposed alternative 
suggested above accomplishes the objective without eliminating what is 
essentially a good system.
     
Sincerely,
     
JP Mark 
     
J.P. Mark
Director of Research
First Security Van Kasper
600 California Street, 12th Floor
San Francisco, CA 94108