From: Kimball54 [Kimball54@rcn.com]
Sent: Tuesday, June 18, 2002 1:01 PM
To: rule-comments@sec.gov
Subject: File No.: S7-22-02 "Insider" Trading

The change in SEC regulations that would do most to restore investor confidence would 
be a requirment that "insider" stock trades be registered in advance.   The notification 
should be a public notice of intent to buy or sell stock coupled with a requirement that
the "insider" actually buy or sell according to the notification.    With a specified
time for advance notice and a time specified to act, stock maniputation would be 
impossible.   As justification for the appropriateness of a "notification" requirement: 
consider that most "insiders" collect a paycheck from the company and stock options were 
intended a perk with an implicit value performance.  With a notice in place; even if the 
books are altered, investors would be forewarned if heavy insider intent to sell is 
publicized.  It is doubtful that requiring a CEO to attest to the validity of the 
corporate accounting alone will be sufficient, (short of a statement of oath with all 
verbiage like "believed to be true" removed and replaced with terms positive like "is 
true").  The SEC must "get it right" this time.  They will not have a second chance until 
the next scandal.  The equities market has lost retail and foreign investors whom may not 
return for years and only if the market appears to be a "fair" table.. 
 
ASIDE:  
1.) When ADR's trade, accounting regulations are beyond SEC regulatory control; conversely, 
trading all stocks is controlled by the SEC. 
 
2.) Company stock "buy backs" and dilutive issuances should fall under the same notification
requirement and a function of the CEO.
 
K. Steven Hall
(508) 490-9900
kimball54@rcn.com