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Author:  Kevin Miller  at Internet
Date:    04/20/2000  5:01 PM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
For the most part, I trade my own stocks. I believe that I should have the 
same information at the same time as the Wall Street analysts. Many analysts 
aren't very adept at analyzing the data, anyway.
     
Kevin Miller
Director of Engineering
CAIS Software Solutions
kevin@atcominfo.com
     


Author:  "Carson Miller"  at Internet
Date:    04/20/2000  9:33 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Equal access to financial information
------------------------------- Message Contents 
Having read information regarding the proposed changes to rules related to 
information disclosure by corporations I would like to voice my opinion to the 
SEC.
     
It is long over due in the time of instant access to information in the world, 
that the nefarious motives of the few Wall Street analysts be overruled, and 
corporations be required to make financial information be made available to all 
investors at the same time.
     
Why as a share holder in ABC, Inc. find out information regarding my investment 
and therefore affecting my decision/planning  process days or weeks after a 
privileged few.  What entitles them special royal status and privilege that 
today's individual investor does not have access to?
     
The analysts are asking for in effect, an excise tariff on information.  For 
once information is no longer new, it's history in today's information age.
     
Get with it SEC and level the playing field now!
     
C. Jay Miller
Roswell, GA



Author:  "Carrie Milne"  at Internet
Date:    04/20/2000  8:28 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sirs:
I have just read part of the text of the above-mentioned regulation at 
http://www.fool.com/news/2000/foth000420.htm
If this is accurate, all I can say is that it is a pathetic attempt by  the 
SIA to guard their own interests, much like a dog will growl if another 
attempts to take some of his food.  I especially take umbrage with the idea 
that I, as an individual investor, am not intelligent enough to analyze a 
company's balance sheets and other information.  Because I am also a 
second-year medical student, I have extensive experience in analyzing all 
sorts of bits and pieces of data that reflect the health of a human being, 
and I can honestly say that analyzing company data to gauge a company's 
health is not much different from what I do every day.  Given that the basic 
analytical skills are something that I have already acquired and am in the 
process of honing as I progress through school, I fail to see how these 
"professional analysts" are magically superior to me in either intelligence 
or any other aspect of life, albeit they more than likely have a 
better-looking bank account from their many years of fooling others into 
paying them high salaries and fat bonuses.  In fact, I would challenge these 
analysts to use their skills in analyzing a human being's health, something 
infinitely more complex than a few numbers on a balance sheet, and then 
perhaps reconsider their position that individual investors are not 
intelligent enough to analyze companies.
     
I urge you to not only disregard this SIA filing as a blatant attempt to 
preserve the handsome way of life of a group of relatively unskilled 
individuals but to also ensure that individual investors have the same 
access to information as these louts enjoy.
     
Thank you.
     
Sincerely,
Carolina D. Milne, MSII
SUNY Upstate Medical University
Syracuse, NY
     
     


Author:  Ajit Moonach  at Internet
Date:    04/20/2000  5:25 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I think individual investors should get the information at the same time 
the analysts get.  Thanks.
     
Ajitpal S. Moonach
     


Author:  "Bob"  at Internet
Date:    04/20/2000  9:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "PROPOSED REGULATION FD: FILE NO. S7-31-99"
------------------------------- Message Contents 
I have the right to make an intellegent decesion regarding market pricing of 
stocks especially if it is my money to WIN or to LOSE. I need the SAME 
information the so called analysts have available and at the same time from 
reporting companys.
     
The alternative model of millions of individual investors pouring over 
prospectuses and periodic reports is not highly theoretical and out of sync 
with real world; just the opposite. We well may be more intelligent, more 
educated, and certainly not as biased as the so called market analysts; AND 
it certainly is NOT true that the analysts make the markets less volatile!
     
And I cetainly don't believe analysts spend much of their time ferreting out 
negative informatrion about companies. They have companys to protect for 
various reasons: they initiated the IPO: they have extensive stock holdings; 
These analysts WORK for a living from  their company, and will represent 
their companys interests or be fired. I know this so why have this cover or 
spin about this great service they provide?
     
Maintaining the current system is in the INTERESTS of Wall Street only, 
certainly not mine. I sincerely hope the SEC will listen to we, the 
investing people, putting our money to work in the GREATEST country on 
earth.
     
Sincerely,
     
Dr. Robert A. Moorehead.
ramoore1@gte.net
     

Author:  "Ron"  at Internet
Date:    04/20/2000  7:01 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents 
To whom it may concern:
I for one, would appreciate timely and accurate information from publicly 
held companies.  I do not generally give professional analysts much 
credibility, as I fear they are controlled by the economics of special 
interests.
Ron Morell
     


Author:  "Ronald Morris"  at Internet
Date:    04/20/2000  6:54 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I believe information should be available to the general investing public.
     
Ron Morris, Greenwood, IN
     


Author:  "Robert Mosher"  at Internet
Date:    04/20/2000  7:03 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I would like to offer the following comments about the proposed regulation as an
individual investor who has come to a painful discovery that listening to 
analyst tell me what needs to be done with my investing is the last thing I need
to be doing.  Since shutting out all analyst information and doing my own 
research, I have tripled my returns for the past two years.  
     
My take of analyst that I see spurting their guff on TV is I wouldn't hire one 
of these guys to run a snowball stand for me.  It seems if these guys are right 
1 out of a 100 times, they want you to forget about the 99 they are wrong.  It 
is likewise hard for the investor to forget about the 99 wrongs though because 
those have hit their pocketbooks.
     
DO I think every individual deserves to hear the information first hand.  If the
constitution is still working, then the answer certainly should be everyone is 
entitled to equal treatment.  In fact, I beleive the concept as currently in 
practice of allowing analyst to hear information first hand definately allows 
for the little man to be stomped in the market.  That he is not, and he can 
still outperform the analyst should be ample proof that the very existance of 
analyst is a questionable need in todays world.
     
Analyst serve to lessen violtility.  Where in the world could that come from 
except the proctectional instincts of an analyst.  Blackout the analyst and 80% 
of the market violitility would disappear.  Take the numbskulls who set $1000 
price targets and glut over the first days of self fullfilling run up in the 
stock.  Or the well known ones who throw out lucky guesses and then are seen as 
guru's because after a few lucky guesses they too live on self fullfilling 
predicitions.
     
If analyst can do such a wonderful job as they have proposed, then we should do 
away with the SEC and Q and K filings and replace it with specific filings with 
analyst.  No need to create all this unneccessary paperwork when it is not read 
or used by the individual investor.
     
Please don't trample any longer the rights of the individual investor in the 
name of an industry that ranks just below the garbage gathers.  If one is a true
analyst, take the raw data, extract meaningful information/direction from it and
present not just your conclusions but back them up with substantial facts from 
the data.  If one desires to be a top notch analyst then do it and be first and 
be right.  Don't expect to be able to drive a modified and faster car with a one
lap head start to protect your incompentancy.
     
EQUAL AND FAIR ACCESS.  HOW UNIQUELY AMERICAN!
     
Robert F. Mosher CPA
7124 Honeysuckle Drive
Biloxi, Ms 39532
     

Author:  "Brian Movalli"  at Internet
Date:    04/20/2000  7:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As an individual investor, I am sending this email to show my support for the 
Proposed Regulation FD rule. I believe that for the market to perform at its 
best, all things related should be done in a fair and indiscriminate manner. I 
absolutely disagree with those on Wall Street who feel that they must be privy 
to important financial information before the masses. I find their reasoning 
that the market would suffer if they did not first review and filter this 
information to be disingenuous. It seems more likely that they are only trying 
to maintain their current advantageous position.
     
The rule appears designed to provide everyone with the same information at the 
same time. I cannot see any rational reason as to why this would be a problem. 
The analysts will still be able to do all the analyzing they want after the 
information is released. The only thing they will lose is early access to 
information which is something no one deserves to have. This special access can 
lead to corruption of the system which breeds skepticism in the public. I 
believe many in the public are already concerned about the role of analysts in 
the market and what their interests are. Passing this rule will curb some of the
public's fears and better serve the market as a whole.
     
Brian Movalli
Software Engineer
Orion Systems
     

Author:  Jim Nellis  at Internet
Date:    04/20/2000  6:29 PM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD
------------------------------- Message Contents 
I absolutely favor this rule as an individual investor.
     
Jim Nellis
OEM Presales Engineer
Direct:  425-936-9397
Fax:  425-936-7329
     


Author:  "Kyle O'Connor"  at Internet
Date:    04/20/2000  5:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
It is unclear to me that enacting the captioned regulation will have a 
negative effect upon the industry and upon my performance as an individual 
investor.  As I reflect upon the investment activities that I have 
undertaken, for my own account, in the past few years I must say that the 
performance of my independently selected investments appears to have been 
better than those that my broker has advocated.  In fact, I firmly believe 
that my broker's sole purpose for calling me is to spout the advice of a 
trusted analyst in hopes that I will deem that advice worthy of placing an 
order through him (essentially a fee in exchange for the information).  
     
That tirade aside, I  believe that the current practice allows an analyst to 
play a role which does more to install market volatility than stability.  It 
is presumed that the analyst's due diligence and fact gathering is done in 
an unbiased and fair manner - allowing all salient facts to be disclosed to 
the public in a succinct and understandable format within the context of the 
industry which the company competes.  However, what prevents that analyst, 
or his/her company, from disclosing that information to significant clients 
prior to the public at large (thereby justifying the value of a fee paid to 
a particular trading house)?  It seems to me nothing.  Further, in this day 
and age where the individual investor values the advice of a broker less and 
less ( due to the power of information gathering that the internet has 
bestowed), we must ask the question if the industry's opposition to this 
proposed rule is based upon their conviction that its bad for investors or 
bad for their future?  
     
As a potential solution, why not require that if an analyst would like to 
meet with a corporation and conduct and in-depth interview a transcription 
of that interview, together with any informational materials handed out 
during the same, must be transmitted to the SEC and posted for review to the 
public on the internet by the company granting the interview. 
     
Thank you for the opportunity to comment.
     
Kyle O'Connor
1222 Taylor Avenue North
Seattle, WA. 98109
     

Author:  Jeff Olfert  at Internet
Date:    04/20/2000  5:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Proposed Regulation FD: File No. S7-31-9
Since information and timing are key to making good investments, I believe 
that all investors should receive equal information at the same time.  Do 
not give investment information to a select group.  Give it to all at the 
same time!
Jeff Olfert
Software Engineer

Author:  "Abdulla"  at Internet
Date:    04/20/2000  7:18 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
I favor an open, fair distribution of marketing information.  Sooner the better.
     
Errol Olson
Box 1764
Round Rock, TX 78681
e-Mail: ErrolTy@Yahoo.Com
     

Author:  "O'MALLEY/ROTH"  at Internet
Date:    04/20/2000  8:53 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I would like to take this opportunity to express my endorsement of the adoption 
of the above proposal.  The securities industry would have us believe that their
analysts alone are able to research and interpret information regarding a 
companies past and future performance.  I would suggest otherwise: as noted in a
recent article in the Wall Street Journal 4/14/00 which dealt with Conseco and 
one analyst who dared question the companies prospects.  His treatment by the 
management of Conseco was hostile and his employer, a brokerage company, was 
pressured to reign him in.  Brokerage houses by their very nature have a massive
potential for conflict of interest.  On one hand they report and interpret a 
companies prospects while on the other hand they court that same company for 
business.
     
Witness the amount of sell recommendations as opposed to buy recommendations by 
brokerage houses.  Are there really that many great public companies available 
to invest in.  I don't think so.  Again as noted in the Wall Street Journal 
article, many analysts choose not to issue a sell recommendation but to down 
grade a stock to a mere hold.  If they can't say what they mean in these 
circumstances, why should we, the investing public, believe that they can be 
honest and fair when they interpret events and prospects in our publicly traded 
companies?
     
Very truly yours
     
Alan O'Malley

Author:   at Internet
Date:    04/20/2000  9:11 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
If you are the guardians of the public interest then you will pass this rule!
     
I can assure you that there are plenty of "experts" willing to interpret the 
comments/statements made by American Corporations and these experts
dont need "private" information!
     
Regards,
Pete Orzech
porzech@mac.com
     

Author:  Otis  at Internet
Date:    04/20/2000  8:29 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I belive that all information should be shared with the public as well 
the analyst.  We are entering a new era in which the general public is 
more informed about financial matters.   I for anything that improves 
the level of information and communication that reaches the general 
public.  In addition, I think it is time we break down the barriers that 
allow Wall Street insiders to have  an inside edge over the common 
investor.  Thanks
     


Author:  William Overholt  at Internet
Date:    04/20/2000  6:27 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
SEC,
     
I support rule "Proposed Regulation FD: File No. S7-31-99".  As an 
individual investor, I don't see any reason why Wall Street analysts should 
be treated any differently than me when it comes to dissemination of 
corporate information.
     
Thank you,
     
William L. Overholt
California
     


Author:  FRED PARK  at Internet
Date:    04/20/2000  6:31 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "proposed regulation fd: file no. s7-31-99"
------------------------------- Message Contents 
Dear policy makers,
    clearly any restriction on the flow of information to the public is
regressive in spirit and sad in action. In the case of the new investor class it
will not work anyway. In terms of publically owned companies the idea is by 
definition wrong. At any rate its too late. Try cleaning up old regs not 
creating new ones.
     


Author:  Milt Parker  at Internet
Date:    04/20/2000  7:42 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: FILE No. S7-31-99
------------------------------- Message Contents 
     
 I support "Proposed Regulation FD: File No. S7-31-99.
     
                                                       Milton L. Parker
     


Author:  "Rudy Patton"  at Internet
Date:    04/20/2000  6:00 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
If we are to make informed decisions, we need as much information as 
possible.  We should have the information that they are giving to a select 
group that benefits by keeping us ignorant.  Why should the SEC approve a 
rule that is not in the interest of the average investor?
     
Sincerely,
Rudy Patton
in Pacific Grove, CA
Thursday, April 20, 2000        5:58 PM

Author:   at Internet
Date:    04/20/2000  9:17 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation fd:file no. S7-31-99
------------------------------- Message Contents 
 I am currently an individual investor and I wholeheartedly support this 
change. I don't need Wall St. analyst working as a go between for me and 
potential companies to invest in. Don't continue to allow analyst to control 
what goes on in the market place by providing them with preferential 
treatment over individual investors. Thanks.                                    
                                Keith Peel Keithpeel@aol.com
     


Author:  "J. Christopher Perdue"  at Internet
Date:    04/20/2000  7:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
This proposed rule (Proposed Regulation FD: File No. S7-31-99) is an outstanding
one for individual investors. 
     
I have taken the time to read the comments of April 6, 2000, by The Ad Hoc 
Working Group on Proposed Regulation FD and the Legal and Compliance Division of
the Securities Industry Association ("SIA"). In reading this document it becomes
obvious why the SIA is the principal lobbying outfit for the full-service 
brokerages.
     
A number of thoughts came to my mind as I read the documents:
     
1) Is it true that "it hardly needs saying that analysts perform a necessary and
valuable function in the U.S. capital markets"? Is it true that to perform that 
necessary and valuable function they need better information than the 
participants in the market?
     
2) Is it true that, the "alternative model of millions of individual investors 
and potential investors poring over prospectuses and periodic reports is highly 
theoretical and out of sync with the real world"?
     
3) Is it true that analysts make the markets less volatile?
     
4) Is it true that analysts spend much of their time ferreting out negative 
information about companies?
     
I think not. I urge you to do the right thing, and approve this rule so that the
public can make more informed decisions with their finances.
     
Sincerely, 
     
Christopher Perdue
1509 Carmel Road
Charlotte, NC 28226
     
    


Author:   at Internet
Date:    04/20/2000  9:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: S7-31-99
------------------------------- Message Contents 
Dear Sirs:
     
I firmly believe that to keep the markets honest all information should be 
disseminated at the same time to the public.  Analysts should not have access 
to confidential information before the public gets access.  The U.S. 
government has always based its principle on fair and open access to the 
public, and that means all the public, not just a chosen few. 
     
Keep the markets open and honest.
     
William E. Perry
Attorney
Washington, D.C.


Author:   at Internet
Date:    04/20/2000  7:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: S7-31-99
------------------------------- Message Contents 
Dear Mr. Levitt,
     
The SIA in trying to justify it's position against proposed Regulation FD 
clearly insults the intelligence of every individual investor in the nation. 
This is really a cut and dry issue. How much more difficult can the concept of 
fairness be? There is no legitimate reason that institutional analysts should 
have access to ANY material data from a company in advance of it's general 
release to the public. It is laughable that they claim they are attempting to 
protect individual investors against themselves. C'mon guys, do the right thing.
It just isn't fair to let these guys continue to have advance info on companies.
There is absolutely no reason why these people should continue to be able to 
sell or buy stocks in advance of general news releases simply because they think
they have the right to come first. Pass Regulation FD and restore some faith in 
common sense.
     
Robet Pistey M.D.


Author:  Jake Poinier  at Internet
Date:    04/20/2000  5:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents 
Dear Sir or Madam:
     
As an individual investor, I applaud the proposed requirement of Fair 
Disclosure of material corporate information.
     
Similarly, I must state my objection to the SIA public statement against it, 
and the reasoning that analysts somehow create market stability. I think 
recent market gyrations suggest strongly otherwise.
     
Please do the right thing and give more information, to more people, more 
often.
     
Thank you,
     
Jake Poinier
Phoenix AZ 
     

Author:  "Price; Mark J."  at Internet
Date:    04/20/2000  6:25 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
The proposed rule is an outstanding one for individual investors and I fully 
support it.
     
Mark James Price MCSD MCT
Desktop Applications Developer
Pillsbury Madison & Sutro LLP
(415) 983-6428
     
     
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Author:   at Internet
Date:    04/20/2000  5:38 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To whom it may concern:
     
Please do not be fooled by the SIA and deny passing the proposed regulation 
FD No. S7-31-99.  For the broker/analyst industry to take the stance that 
they are protecting the public from ourselves is utterly ridiculous.  They 
are only trying to hold onto to their "monopoly" of information and then 
charge the said public for that "public" information.  If a company is 
"public", then make it just that and require companies, among other things, 
to not be selective in who sees their "public" information.
     
One more note, the SIA would have you believe that analysts keep the market 
less volatile.  Well first of all, by the analysts hoarding the 
information, the markets are most likely MORE volatile due to the unknown. 
Secondly, to state that the public can not handle certain information is 
also a misnomer.  By making sure the public gets accurate information 
(negative or otherwise) will only make companies and their employees more 
accountable.  Gee, what a concept!
     
Thank you for your time and consideration of this issue.
     
Will Rehbaum
Financial Analyst
Canon Computer Systems, Inc.
     

Author:  "Harald Reksten"  at Internet
Date:    04/20/2000  8:17 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I believe in fair and full disclosure of company information to all investors. 
For too long the "so called" analysts have had access to information that the 
individual investor does not have access.  I certainly do not want company 
information filtered through "analysts".   Please accept the new regulations. 
Thank you. 
     
Harald Reksten
35 Winding Hill Drive
Hockessin, DE 19707 
     
"A concerned small investor"   


Author:  Theresa Riccardo  at Internet
Date:    04/20/2000  9:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents 
I support the passing of this regulation. 
Theresa Riccardo
     

Author:  "Norm Rittenhouse"  at Internet
Date:    04/20/2000  8:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am IN FAVOR of all investors having access to the same information as the 
analysts.
     
Better informed investors make for more stable, healthier, markets.
     
The recent market crash is amble evidence of uninformed, follow the analysts 
trading.
     
To suppose that we need those self serving analysts censoring our news is 
ludicrous.
     
Norman Rittenhouse
Fairbury, IL 61739
     


Author:  "Mike Robey"  at Internet
Date:    04/20/2000  8:12 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
To Whom It Should Concern:
     
First let me say that I support individual investors being provided with all 
information released by a company.  It is profits and unfair opportunity the SIA
supports rather than any other statement that they make. If, as an individual 
investor, I need an analyst opinion I will seek it. If not--contrary to their 
implied statements--I will make my own decisions, thank you. I feel that not 
disclosing information to the pubic because of an implied ignorance of the 
public is arrogant and condescending. I also thought that there were insider 
trading rules that the SEC is supposed to enforce. Is not limiting information 
to the so called elite not insider trading? To you the SEC I say to check these 
analysts historical accuracy. I believe that disclosing information to all, at 
the same time, would not make a more volatile market but, a more stable one. We 
would not have to react to their so called "expert opinions".  We could 
interpret the information, or learn how to. Please let them (SIA) know that the 
"times are a changin". Their protected world is being invaded by a smarter and 
better informed public, and this is good.  
     
     
Sincerely,
     
     
Mike Robey
     


Author:  "Teri Rogers"  at Internet
Date:    04/20/2000  6:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: citizen testimony
------------------------------- Message Contents 
I am an investor.  Have been for some time.  Finding information about 
investments is a task I enjoy.  Good information is hard to get, and I have to 
work hard digesting SEC filings, prospectuses, financial press, etc.  Same as 
everybody else, almost.  
     
I have a full service broker that charges 40 times what I pay to an online 
account for a trade.  I use the full service guy on occasion, because he seems 
to have 'information' that I am unable to get.  He has analysts that work for 
his firm that have the privilege of speaking directly to the management of many 
firms.  They do not pay for this 'first' information but they do charge for it. 
     
     
I believe that the information can have the potential of being held, or 
modified, depending on the nature of the stock holdings of the employer of the 
analyst.  
     
Level playing field?  That is a joke.  Stocks move five days prior to any 'after
the close' announcement.  The people with access to information make money off 
the people who don't.  They buy the stock first (or sell it, or short it), then 
inform the general public, or clients ( whom they charge).  Giving equal access 
to information is only fair.  If equal access to information about public 
companies is determined to not be in the publics best interest then you simply 
perpetuate the 'who's your buddy' system we currently have.  If it doesn't make 
a difference to the markets, then let the analysts go in last.  It shouldn't 
make a difference.  I think a lot of people are being taken advantage of in this
current system.
     
John Rogers
     

Author:  David Rohde  at Internet
Date:    04/20/2000  8:56 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Full disclosure
------------------------------- Message Contents 
For what it's worth I am adding my opinion to the mix. There 
is no doubt that there are some investors who would 
misinterpret the data given them and make mistakes with their 
investments. There is also no doubt that some citizens 
misinterpret the facts and make poor decisions on election 
day. Neither of these however are reasons to withhold 
information from citizens in a free society. Information is 
power and any time that much power is concentrated a real 
danger persists that some people will abuse that power. That 
reason is the reason the First Ammendment exist that way they 
could make sound decisions in their best interest based on 
fact not the opinion of the the learned.  The free enterprise 
system is the root of true freedom in any society and that 
freedom is threatened when a small group of people exercise 
control over information used to make economic decisions. For 
these reasons please rule in favor of full disclosure.
Thank You
David Rohde
     

     
Author:  Eric Rohrbach  at Internet
Date:    04/20/2000  6:51 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: rohrbae@yahoo.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
     
To whom it concerns,
     
I believe that all fair disclosure of information by 
publicly traded companies, Proposed Regulation FD: 
File No. S7-31-99, should be disseminated to the 
public at the same time it is to the "Wall Street 
Analyst".  Does the government represent groups or the 
public?  I believe the only interest that Wall Street 
has by lobbying to keep this information to themselves 
before it goes to the public is for there own 
financial gains. Most individual investors understand 
the market as well as these "Wall Street Analysts". 
To equal the playing ground make this information 
accessible to all at the same time.
     
Regards,
Eric Rohrbach
170 Bascom Rd.
Lebanon, CT 06249
     

Author:  Lee Rombough  at Internet
Date:    04/20/2000  4:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: No. S7-31-99
------------------------------- Message Contents 
I have managed my own retirement funds for the past decade ana have done 
quite well. The interesting point is that the shares that have performed 
the best have been those that I have found and researched. The ones that 
are doing poorly right now are those that my broker advised me to buy 
based upon his company's research. 
I am not a genius nro do I have the skills that some others do, but I 
find out the downside points much bettrer than what I get from 
professional investment counsulors. 
I would appreciate being able to have the same information that is 
available to the brokerage houses. I have yet to find anyone who takes 
the same amount of interest in my success than I do.
I will appeciate your votes for this proposal.
     
     

     
Author:   at Internet
Date:    04/20/2000  9:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: (no subject)
------------------------------- Message Contents 
     
     
I support the proposed rule.
     

     
Author:  Richard Sayer  at Internet
Date:    04/20/2000  4:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
I have reviewed the public comments of April 6, 2000, by The Ad Hoc Working 
Group on Proposed Regulation FD and the Legal and Compliance Division of the 
Securities Industry Association ("SIA") and cannot believe the arrogance and 
self interest presented there.  The SIA argues that individual investors are 
not intelligent enough to make their own decisions about the value of 
securities and need Wall Street's analysts to hear and interpret important 
information first. Through that method, the SIA argues, individual investors 
are protected from their own ignorance and emotion.  
     
I am an individual investor and make all my own investing decisions.  I do 
not look at Wall Street Analysts reports at all.  In fact, I am very upset 
to see analysts making earnings predictions, have it broadcast, seeing the 
price of a stock run up and then later drop.  In fact, I suspect the 
information provided to the analysts allow them to profit at the expense of 
the individual investor.  
     
I encourage you to "level the playing field" and help eliminate the current 
abuses and inequities in the system.
     
Thank you,
     
Richard L. Sayer
10935 Tulip Pl. NW
Silverdale, WA  98383
     
Email  rlsayer@silverlink.net  
     
     

     
Author:  "Richard T. Schachner"  at Internet
Date:    04/20/2000  9:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Fair Disclosure
------------------------------- Message Contents 
I support the Fair and Full disclosure rule now under consideration. 
Sincerely
Richard T Schachner
10929 Loudoun Lane 
Charlotte, N.C. 28262
Rschachner@carolina.rr.com
     

Author:  "wschafer"  at Internet
Date:    04/20/2000  8:26 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REG FD: FILE NO. S7-31-99
------------------------------- Message Contents 
Gentlemen:
        I find it incredibly unjust that " analysts" are privy to public company
information before all stock holders and citizens  have access to it. The 
argument that we need their ability to analyze the information is facetious. 
If one wishes they may use a brokers advice but if he prefers not to he 
should not be at a disadvantage by receiving such information after others 
who may use it to there gain.
        Please see that this situation is corrected.
     
Sincerely yours,
     
Walter J. Schafer
6483 Eastpointe Pines Street
Palm beach Gardens, Fl. 33418
wschafer@adelphia.net
     
     

     
Author:  Linda Schoenfeld  at Internet
Date:    04/20/2000  7:23 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No.
------------------------------- Message Contents 
Please
     
Lets have fair disclosure for all parties, analysts and the INTERESTED 
PUBLIC!!!!!!!!!!!!!!!!!!!!!!!  Anything less is criminal.
     
Thank you
L Schoenfeld
Nashville, Tn
     
     

     
Author:   at Internet
Date:    04/20/2000  9:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
Gentlemen,
It is time to level the playing field.  Let's no longer punish or 
disadvantage individual investors who do their own analysis.  It is the 
height of arrogance and condescension to hold that there should be a select 
few to interpret financial news.  
     
Sincerely,
Doug Schongalla
     

Author:  "Schroeder; Ian E"  at Internet
Date:    04/20/2000  6:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As a small individual investor, I have only about $30,000 in individual stocks. 
My retirement savings are in managed funds.  I try to keep investment fees to a 
minimum, which means that I use an on-line discount broker.  I don't spend money
on the reports that analysts generate.  I don't dispute the fact that investors 
willing to spend the money should be able to purchase analysts' services. 
However, these services should consist of organizing, interpreting, and 
presenting data that is available to all investors.  I shouldn't have to 
purchase the raw information provided by a corporation to an analyst, however, I
am willing to pay the cost of publication.  For example, even though the news is
free, I still have to pay for a newspaper.  In the digital world, I may have to 
pay a fee to be hooked up to the internet, or have a subscription to an on-line 
newspaper, but I don't like having to pay $20 to purchase a report where an 
analyst reveals information that is new to the publ!
!
ic.  The analysts' skill in interpreting information provided by management is 
theirs to sell.  The information itself is public, and not for sale.  All 
statements made by a corporation's mangement,when made to a member of the 
investment community, should be readily available to the investing public for a 
fee no greater than the cost of disseminating those statements.  I shouldn't 
have to purchase the analysts' product to have access to "public" information.
     
Sincerely,
     
Ian Schroeder
jannee@drizzle.com
     
     

     
Author:  Faith Sheridan  at Internet
Date:    04/20/2000  7:52 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File#57.31.99
------------------------------- Message Contents 
I am opposed to this  regulation.
     
Faith Sheridan, FSID
     
     

     
Author:  "Ric Shumway"  at Internet
Date:    04/20/2000  6:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I feel very strongly that the following rule is the only fair way for company 
information to be disseminated.  Please make sure it passes.
     
"The rule (Proposed Regulation FD) would require, among other things, that 
companies no longer engage in the practice of discreetly disclosing important 
information to Wall Street analysts without also giving that information to the 
public at large."
     
Sincerely,
     
Ric Shumway
8757 Dove Tree Lane
Elk Grove, CA 95758-6791
916.313.3535
     
     
     

     
Author:  "Michael D. Simmons"  at Internet
Date:    04/20/2000  9:15 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
This regulation should pass!
     
Michael D. Simmons
     
Individual Investor
     
     

     
Author:  "Bob Slater"  at Internet
Date:    04/20/2000  8:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Folks,
     
I am a small, individual investor.  I am STRONGLY IN SUPPORT of your proposed 
ruling to "level the investing playing field."
     
Please follow through with all gusto.  Your efforts to clearly put the ability 
to assess public entities in the hands of those making the investments are sound
and reasonable.  They appeal to all levels of logic.
     
Kudos, and good luck.
     
Bob Slater
     
     

     
Author:  larry slobodzian  at Internet
Date:    04/20/2000  6:11 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To whom it may concern:
      I am an average, small time investor. I use investing to finance
my retirement, my children's education, and try to increase my net worth 
as much as possible. I do not participate in mutual funds. I do not have 
a personal broker. I do my own research, and use a deep discount broker 
to make stock trades. I am a "Motley Fool". I do not trust industry 
analysts or brokers to make my decisions or offer advice because they 
are biased. They make their money on how many trades I make, not how 
well I profit. Without any formal training or certification, I return 
over 35% per year on my money. 
      The more accurate, unbiased information I have available to me,
the better financial decisions I can make. That is why I support the 
proposed measure that will force public companies to reveal publicly 
what they have been releasing privately to analysts. These analysts, 
through the SIA, have said that if this occurs, the markets will be more 
volatile. I say that if the measure is not approved, they will maintain 
their power to influence market decisions by "translating" their inside 
information to the rest of us.
      Our country was founded on the belief that all people have the
ability to make their own decisions, and that the government should not 
allow anything to stand in their way. This proposed regulation will make 
that possible, by treating all investors the same, rather than giving 
special treatment to the Analysts/Insiders.
      The SIA's opposition to this regulation is based on the fact that
their jobs will be in jeopardy, because we will not need them as much if 
we have the same access to information. Please make the decision on the 
side of the people, not the Wall Street insiders. Pass Proposed 
Regulation FD: File No. S7-31-99.
     
Thank You, 
Larry Slobodzian
Senior Network Operations Specialist 
Sprint BTSD
913-534-7676            
     
     
     

Author:  John Lleweilun Smith  at Internet
Date:    04/20/2000  7:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sir/Madam,
     
I just wish to say that I hope this goes through.  Institutional investors 
should not be privy to information that we small investors are not.
     
Lleweilun Smith
Rice University
     
     
     

     
Author:  "Cheri Smith"  at Internet
Date:    04/20/2000  9:15 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: 
------------------------------- Message Contents 
TO BIG GOV/BIG BUSINESS
FD:  File No. S7-31-99
     
I do not need you making my financial decisions for me,  thank you!!!  In fact I
would appreciate it if you would stay out of my business.  I believe the Sec 
ruling on needing analysts involved in the market, is for one interest and one 
interest only,  the best interest for the big guys!  Anaylsts drive the market 
to hugh swing and all of this is to set the stage for their pocket book.  Do not
think for a minute that this game fools the public at large.  We know very well 
what is going on.  WE DO NOT NEED THE ANALYSTS MAKING OUR CALLS FOR US.  THANK 
YOU
     
Cheri Smith
r-cs@juno.com
     
     

     
Author:  "Jason Smith"  at Internet
Date:    04/20/2000  7:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
First, let me tell you about myself.  I am a computer programmer with a 
background in electronic design.  I use the internet heavily to gather 
information on companies, information that was once very difficult to get 
unless you were a broker.  I invest by researching companies and then buying 
and holding the best ones I can find.  I do not "day trade".  I do not own a 
single high-flying internet bubble stock.  I used to put everything I 
invested in mutual funds, but since I started investing in individual 
companies, I have outperformed my old investments by a large margin.  I did 
this without a broker and without the advice of the professional analysts. 
My ability to invest successfully depends on my access to relevant, timely 
information, and the absence of insider information.
     
This proposed regulation is ridiculous.  INFORMATION IS POWER, and this is a 
last ditch effort to take away some of my power to make my own decisions.  I 
don't want or need a paid analyst to read the news to me simply because I am 
not in the "inner circle" of Wall Street.  This proposed regulation is 
inherently unfair to individual investors.
     
From the SIA filing: "It hardly needs saying that analysts perform a 
necessary and very valuable function in the U.S. capital market."
     
So why do they need a competitive advantage, against me, mandated and 
endorsed by the government?  If they added so much value, I'd use them.  I 
don't use them because I do not believe they give me any advantage in my 
investment decisions.  They know I am out here, and they know there are 
millions of other people like me, people who know that analysts don't really 
know any more than we are capable of learning through due dilligence and 
research.
     
Also: "alternative model of millions of individual investors and potential 
investors poring over prospectuses and periodic reports is highly 
theoretical and out of sync with the real world."
     
I work for a living.  I pay taxes, I own my own home, and I have a Masters 
Degree.  I do all my own research.  I have a cat and a lawn.  I am in the 
real world.  I make decisions concerning my own money every day that have 
nothing to do with the stock market.  I can make decisions for myself as to 
what companies to invest in.
     
Also, analysts use the same information I have.  They use balance sheets and 
cash-flow statements.  They use the news they read.  Many of them do not 
understand the technologies they claim to analyze - they are business 
majors.  They never studied theoretical physics or electronics theory, and 
many have little or no interest in science.  What qualifies them to filter 
information to me?
     
Also: "Leveling the playing field for analysts, as among themselves and 
vis-a-vis the general public, will undermine the great advantages of the 
current system."
     
This only undermines the current system of insider information.  Leveling 
the playing field is a good idea.  Otherwise, insider information would be 
illegal.  Wait a minute ... it IS illegal!
     
Also: "But it is also the few analysts operating independently of, and in 
competition with, each other that can relentlessly pursue an independent 
line of inquiry and ferret out negative information that management would 
rather not disclose or would prefer to disclose at a time of its choosing 
and with its own spin. They can glean information from changes in the level 
of confidence (sometimes evidenced in subtle ways such as changes in choice 
of words or tone of voice) over a series of telephone conversations or 
face-to-face meetings. They can test their hypotheses by comparing 
information about different issuers in the same industry or sector."
     
That is a long one, but the guy who wrote this stuff was pretty wordy.  This 
is just like when I listen to a conference call over the internet and then 
add my questions by e-mail or chat room.  This is a very weak argument.  It 
is an argument to exclude the general public from information that should be 
available to everyone on an equal basis.
     
If an analyst has negative information about a company, he can advise his 
friends to quickly sell.  They have an advantage over everyone else.  The 
analyst would not be legally obligated to give equal consideration to 
everyone, and that is insider information.
     
"Due to fierce competition among analysts to obtain the best information, 
they will be reluctant to ask questions in an open session that tip off 
their competitors as to the direction of their thinking or information that 
they think would be meaningful. If the questions cannot be asked in private, 
they may not be asked at all. Is that good for the market?"
     
We have freedom of the press to take care of asking the hard questions in a 
public forum.
     
That is not what this is all about.  These guys want to be able to have 
private meetings with company officials where they can learn non-public 
information ... without tipping off the general populace.  This would allow 
them to act as "insiders," buying before the big announcement and selling 
before the big disappointment.
     
This would encourage company officials to deliberately withhold information 
from the public until "favored" analysts had a chance to be briefed.
     
It would also lead to a huge information gap in the market place.  The 
"haves" would be a step ahead of the market at every turn.  The "have-nots" 
would be forced to buy information from the "haves" or face the very real 
possibility of losing everything on what might have otherwise been a sound 
investment strategy.
     
This is wrong.  Wrong, wrong, wrong.  It is NOT in my best interest to be 
legally kept in the dark for my own good.  I am an adult, and I can make my 
own investment decisions.  It is not good for the market to show favoritism 
to a select few individuals.  It would allow market manipulation similar in 
scale to that which occurred in the late 1920's, in my opinion.  More 
subtle, yes, but it is still large scale market manipulation any way you 
look at it.
     
"We believe that communications between [a company] and individual analysts 
or small groups of analysts contribute to the overall mix of information in 
the marketplace, greater accuracy of market prices, less volatility and, in 
general, greater efficiency...."
     
No.  Let the news media handle the tough questions.  Let the analysts read 
the same news I read.  Don't give the analysts the upper hand against 
everyone else, because they WILL USE IT, and millions of men and women like 
myself will suffer for it.
     
Thank you.
     
Jason Spencer Smith
Consultant
Creative Concepts Corporation
     
Voice:  303-448-0303 x237
Fax:    303-448-0205
Web:    www.creativecorp.com
Email:  jason@creativecorp.com
     
     

http://www.sec.gov/rules/0420b03w.htm


Modified:04/27/2000