Date:    03/21/2000  9:07 PM

Subject: Proposed Regulation FD

Dear SEC --
     
I speak as a private investor and a hedge fund manager.
     
I believe the proposed "Fair Disclosure" regulation would serve to level the 
playing field
so that all investors would receive more or less the same information at the 
same time.  While abuses would probably still occur even under the proposed 
system, I think it would be a great improvement over the current system.
     
To those who are concerned about the effects this regulation would have on 
industry, I would ask that they look at the track record of some of our leading 
technology companies such as Microsoft, Intel, Dell, and Cisco.  These companies
have taken the lead in many if not all of the elements in the proposed 
regulation by putting their conference calls and occasionally even their 
shareholder meetings on the Internet, by putting speech transcripts on the net, 
etc.  For all but the smallest of companies, the cost of full disclosure is 
quite minimal given the ever lower cost of using the Internet.  Will the 
information be occasionally misinterpreted?  Perhaps, but no more so than goes 
on now with selective disclosure and rumor mongering on bulletin boards.
     
Investing is difficult even with full disclosure.  Without it, though, investors
have played with one hand tied behind their back.  If WallStreet wants to earn 
their fees, they need to add analysis and not just report the facts that any 
investor can get from a company themselves.
     
Thank you for considering my opinions.
     
-- Bradley Richardson, co-manager, The Nibelung Fund LLC