Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Allen; Joy" at Internet
Date: 04/21/2000 6:21 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD; File No. S7-31-99
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To whom it may concern, I find it hard to believe that in this country we do
not require fair disclosure of information by a publicly traded company.
The rule proposed by the Securities and Exchange Commission (SEC) regarding
the fair disclosure of information by publicly traded companies to the
public, should require companies among other things, to 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. It's a
pretty common sense rule in my opinion. To think we as investor are unable
to use this information intelligently is an insult to me as an investor. We
as individual investor should be given the same information as brokers on
publicly traded companies.
Joy M Allen
Author: "richard" at Internet
Date: 04/21/2000 8:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Total public access to company information.
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The rebuttal to open disclosure by analysts is ridiculous. If I may paraphrase
they said "They could not envision millions of investors pouring over data and
other types of information".
What they(analyst) have forgotten is that an investor does have choices. Having
all the information does allow the investor to do as much research and
investigating as he or she wishes to do. If on the other hand the investor
wishes to follow the recommendation of an analyst that is also their free
choice. The important point here is that all are starting from the same
position.
Another point brought out by the analyst in their argument is that they are able
to discern truth from fabrication by analyzing voice inflection and body
language. How many analysts have degrees in psychology?
R. Audette
Author: nathaniel barber at Internet
Date: 04/21/2000 3:27 AM
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TO: RULE-COMMENTS at 03SEC
Subject: free flow of info
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how abou this idea. put the information out for us, the public, and let
us decide its worth.
nathaniel barber
Author: Mark Beckner at Internet
Date: 04/21/2000 7:33 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I believe that equal access to information about publicly traded companies
is one of best things the SEC could provide to an individual investor such
as myself.
Please count me IN FAVOR of Proposed Regulation FD.
Sincerely,
Mark Beckner
An Individual Investor
Author: "Hugh Beebe" at Internet
Date: 04/21/2000 6:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Regarding Proposed Regulation FD: File No. S7-31-99
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Requiring that that companies must disclose important information to to the
investing public whenever they disclose information to Wall Street analysts
is the surest way to protect the market from manipulation by analysts. The
expertise of analysts should properly lie in their ability to extract from
the publically disclosed information stream the most meaningful information
and to derive the best conclusions from it. Access to privileged
information is not expertise at all. Thus public disclosure will not only
protect the market and the public, but should result in a heightened level
of true expertise from more diligent processing of that information.
Hugh G. Beebe
Author: rbeffa at Internet
Date: 04/21/2000 6:48 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC, As an investor, I support a requirement for all companies to
provide equal disclosure to all of the investing public. There is no valid
reason, for the institutional brokerage houses to receive privileged
information. We live in the information age in a country with a free market
system that needs to remain free.
Ray Beffa
Author: "Rick Beggerly" at Internet
Date: 04/21/2000 7:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Selective Disclosure
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Re: Proposed Regulation FD - File No. S7-31-99
As an individual investor I am 100% in favor of this legislation. I personally
cannot see where there is much room for discussion. It seems that you should
either stop all ability by the individual investor to purchase stocks on his/her
own
(electronically via the web, etc.) and force us to go through a broker to
protect us
from ourselves or pass this regulation and allow us more complete information
to make an informed choice.
Below are two links by individual investors whose comments are eloquent, but
directly
to the point, and express not only my feelings but I am sure many other
investors.
Thank you for a chance to express my opinion.
Regards,
Rick Beggerly ILEC Products Manager
NeXband Communications
Voice: 601-353-2001 x 2090
Fax: 601-353-6465
rick.beggerly@nexband.com
Author: Bryce Behunin at Internet
Date: 04/21/2000 7:45 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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The stock of public companies is being traded on the open markets by
individuals who do their own research and make their own decisions, without
the clouded interests of analysts and brokers. As public companies are
"Public," it is in the best interest of everyone involved that all
information be make public to everyone at the same time. The individual
investor is entitled to any information that affects his/her stocks and
should not be put at a disadvantage because he/she is "not smart enough" to
understand and evaluate all the information. Most Americans who venture into
the stock market understand the importance of proper research. Should we be
penalised because a few analyst think we're too stupid to think for
ourselves? I don't think so. Give us what we, the public, deserve, free
access to allow us to make educated decisions on companies that we trade.
Don't give into lobbyists whose only desire is not to better serve the
public, but to better serve and protect their pocket books. Pass this rule
which will give us what is rightfully ours, public information about public
companies, when and as it becomes available.
Bryce Behunin
behunbo@ecite.com
Author: "Jim Bishop" at Internet
Date: 04/21/2000 8:07 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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SEC:
I encourage you to pass the proposed regulation providing for fair disclosure of
information by publicly traded companies to the public at large. In today's
Internet age, anything less is illogical, inefficient, and unfair.
Jim Bishop
1782 Millhouse Run
Marietta, GA 30066
(678) 445-7901
Author: at Internet
Date: 04/21/2000 8:36 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As I understand this, I believe the fact that the securities industry is
against it is the best reason to put the rule in place. The big investment
houses should not be able to obtain information that is not available to
the general public.
Can you imagine this scenario. An investment house gets some negative
infomation during one of these conference calls. So they tell their
representatives (read sales people) to push to have investors buy that
stock so they can get it out of their in-house portfolio. The reap the
profits while the stock is still high and then when the news finally
becomes public, the stock drops, saving the in-house portfolio from taking
a significant hit.
Jim Bland
703-418-2295
Author: "William Blitch" at Internet
Date: 04/21/2000 8:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I read with great interest the comments by the SIA posted on the Motley Fool
site. It seems to me that the securities analysts believe their function is
essential to the well being of all investors. My experience has proven the
opposite. It seems to me that many of the analysts and the full service or
should I say self serving brokers they represent are in the business of selling
stocks and making money. Who is it they make their money from? Answer, the
individual investors. Of course they believe it will be the end of the markets
as we know them because they will no longer be able to make a buck off of the
individual. I am all in favor of people making money. But, I believe my
ability to make money is most important. Wall Street needs a level playing
field. There is no reason why analysts cannot get the information the same time
as all other investors and then they can disseminate it to the customers that
they are able to maintain. These full service brokers will always have people
that are not willing to make decisions for themselves, or are to busy elsewhere
to worry about their investments. Unfortunately, the vast majority of investors
do not have this luxury. We believe in carefully selecting our investments. I
will now respond to some of the comments made by the SIA.
"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...."
Why would this not take place if the information is distributed to everyone at
the same time. Seems to me that the more information that the more people have
the more efficient and accurate market prices will be for everyone. I realize
that their efficiency includes them being able to make a few dollars before
everyone else can, but true efficiency and accuracy in pricing results from full
and total dissemination to everyone and not to a select few who plan on giving
us non-professionals their spin on reality.
"It hardly needs saying that analysts perform a necessary and very valuable
function in the U.S. capital market. They, together with the media, are the
principal way in which important financially significant information (including
information contained in prospectuses and reports filed with the Commission)
effectively reaches most investors and gets reflected in the marketplace. 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."
What real world are they living in. Individuals spend hours sifting through
company information available over the web. One look at the Motley Fool web
site's discussion board shows the vast interest by individual investors in the
information provided by companies. People are not mindless
investors...excluding day trades which wouldn't care about the information
enough to read it anyway. As for analysts and the media being the principal way
investors get the information they need, I feel this is becoming less and less
true. I, for one, like to look to an individual companies web site, their
financial reports filed with the SEC and any other document I can get my hands
on that came straight from the company before I look to see what analysts have
to say. I think the "alternative model" will put many analysts in a hot seat.
If they can't decide what is important, the millions of individual investors
will be able to decide for them. This scares them to death. God forbid they
can be proven wrong by the masses.
"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. This kind of work results in more continuous disclosure,
fewer surprises and less volatility. The marketplace itself provides incentives
for such diligence, for it is the analysts who get to the market "firstest" with
the "mostest" that under the current system reap the reputation and financial
rewards. 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."
I am amazed by the fact that the SIA would use as one of its reasons for not
allowing individual investors access to information at the same time as analysts
that analysts would not have the advantages that lead to their reputation and
financial reward. While this is probably the most accurate reason they can
give, it is probably the worst possible reason of all. How can leveling a
playing field for analysts and the public undermine any great advantage in the
current system. The only possible advantage that can be undermined is the
ability of full service brokers and their analysts to make a quick buck before
the individual investor even knows what is happening. I take great concern in
the fact that brokers and analysts feel themselves in a position where the
market owes them something. They argue that the only reason the market is what
it is resulted from them and not the individual investors. Yes, their great
advantage would be eliminated, but why is it appropriate for a system that is
striving to be efficient and promote price accuracy allow and subsidize a great
advantage for any select group.
The above quotes are as appears in the article "Wall Street Opposes Level
Playing Field" by By Bill Barker on April 20, 2000 on
http://www.fool.com/news/foth/foth.htm
I understand the importance of this issue to the analysts and full service
brokers. However, it is time that a select few are no longer privileged with
information prior to the rest. If market efficiency and greater transparency of
information is what is desired then there can be no better way then to 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.
With great concern,
William Blitch
Who are a little wise the best fools be.
The Triple Fool
by Dr. John Donne
Author: "R & T GB" at Internet
Date: 04/21/2000 8:26 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I should have access to the same information as anyone and everyone else.
What I choose to do with it is my business.
The logic that only 'real analysts' should be allowed certain information is
the same as saying only accountants should be given certain 'tax law
information', such information could be misleading to non accountants, yet
millions continue to their own taxes without the information.
COMPLETE DISCLOSURE - seems simple to me!
Tricia G. Boelter
6 Chase St. Massena, NY 13662
Student - SUNY Potsdam
39 years old
Author: "Michael J. Bonnette" at Internet
Date: 04/21/2000 8:55 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Rules need changing
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I am an individual investor and have been active for years. In my opinion, the
information companies pass out should be passed out to ALL, and simultaneously.
In the pre-networked ages (which are gone now, since all serious individual
investors are online) the good-ole-boy network of passing information through
the analysts filter was a method that appeared to work.
Personally I have not been all that impressed with analysts and have been led
astray by them. I would much rather have all the information available and sort
and sift through the information I feel relevant and important. the library of
investment books I own and have read prepare me to do this. I addition there is
so much help and real time capability on line that there is no logical reason or
argument to withhold any information as it relates to an investor placing money
with a company.
If you really have the interest of the investing public at heart, then LET US
CHOOSE. Do not choose for us.
Thank You.
Michael Bonnette
Individual Investor
Author: at Internet
Date: 04/21/2000 3:58 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD
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The Ad Hoc Working Group on Proposed Regulation FD and the Legal and
Compliance Division of the Securities Industry Association ("SIA") declares in
their Overview many companies are in favor of increased disclosure and there
is a significant increase in open disclosure of information.
Disparity of disclosure is currently insured. By establishing the
requirement to file Form 8-K it will lessen the current information disparity
disclosure. Currently information is given to selected individual for what
is considered a justifiable reason and not in conflict with the law.
Initiating Regulation FD will probably create an increase of reliable
information, as business will now be required to disclose truthful statements
instead of intentionally misleading the market with planed rumors. This will
help create a stable market.
I do agree a measurable standard should be established as to when the 24-hour
period starts for an issuer to publicly disclose the information.
Foreign Government and Political Subdivision Issuers should comply with
Regulation FD. Foreign private investors also need to comply. Defined,
measurable consequences need to be established for parties not compliant.
As with all new laws, interpretation of the intent will be established
through time and circumstances.
This does not mean the FD Regulation should be discarded. Worthy changes
take effort.
I sincerely believe this will assist in a more stable market and reduce the
confidential inside trading supported by the selected release of information.
The analyst will adjust and the majority of investors will continue to use
them. The self-investor will have access to more reliable and timely
information.
Author: "Boyenga; Jerry I" at Internet
Date: 04/21/2000 8:16 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs,
I fully endorse the proposed rule for full disclosure. I believe that
the general public should not be at a disadvantage to those with more
immediate access to analysts and their more comprehensive information on
public companies. Nor should the public be subject to information filtering
and spin by analysts of dubious qualification.
Let's face it, the current system gives unfair advantage to a few. No
matter how fast an analyst's report is posted on the internet it is already
"old news" to those on Wall Street. If "analysts perform a necessary and
valuable function in the U.S. capital markets" it is only because of the
unfair advantages they are operating under. If you provide for full
disclosure, those analysts who really who perform will do well and those who
just got the news first will leave the scene. But we will all make
investment decisions under a more fair system.
Jerome I. Boyenga
Individual investor
Author: "Jim Brown" at Internet
Date: 04/21/2000 5:17 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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As president and owner of my own business I find the filing by the SIA to be out
of touch with reality and obviously self serving.
Given the current trends in investing it is obvious investors should be given
access to the same information as those in the investment community.
The public does not need "protection" from corporate information. Level the
playing field.
Jim Brown
President
Uland Supply Co., Inc.
Louisville, KY.
502-587-0721
Author: "smb" at Internet
Date: 04/21/2000 7:30 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I consider this proposal extremely important for the American investor. It is
almost obscene the way certain market makers trade or especially made
recommendations with inside knowledge.
Thank you
Steve Bryant
Author: "Sara Burns" at Internet
Date: 04/21/2000 7:48 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom It May Concern at the SEC,
As an individual investor, I find the SIA's April 6 public comment
on the proposed regulation concerning Selective Disclosure and
Insider Trading disengenuous and dangerous.
Anyone who keeps tabs on the financial press knows that, even
with access to information the public does not have access to,
many securities analysts are wrong in what they think and say and many
stockbrokers and mutual fund managers still can't do better
for their paying clients than the market average . Since I am one of
the millions of individual investors who consistently do better than
the market average, I know it's possible to accurately asses the
vast amount of complex information about stocks and economics
without being a professional analyst. Don't give in to the
analysts and try to protect me from this supposedly harmful
information.
Please interpret the SIA's comment for what it is: an effort to keep
important information from the public - an effort to try to quell
the embarassment and they must feel about no longer being necessary
to millions of American investors. These professionals have done
poorly even with the odds in their favor, and their sense of
entitlement to continue doing so is a grave disservice to
the American public.
Sincerely,
Sara Burns
Sara Burns
P. O. Box 758
Perkins OK 74059
(405) 547-8368
(508) 302-7917 fax
Author: at Internet
Date: 04/21/2000 8:33 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support this proposal.
Eric W. Carman
Author: "Christiansen; Paul" at Internet
Date: 04/21/2000 8:33 AM
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TO: RULE-COMMENTS at 03SEC
CC: "'news@fool.com'" at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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I recently wrote a soon to be published book about the securities industry
(Be Your Own Broker). One entire chapter has been devoted to the
anachronism of the analyst system. Contrary to the contention of the SIA,
most intelligent investment industry observers would probably agree that the
existing analyst system contributes greatly to chaotic market conditions.
Aside from being elitist and abysmally undemocratic, it is one of the
cornerstones supporting the unwarranted or unearned accumulation of vast
personal wealth on Wall Street, ergo their pathetic and transparent attempts
to convince the SEC to preserve the status quo.
There are no elevators to the house of success -- you must climb the stairs.
Paul Christiansen
8*227-9815
(716) 347-9815 (Voice)
(716) 347-9602 (Fax)
Paul.Christiansen@usa.xerox.com
855-01B
Author: at Internet
Date: 04/21/2000 8:31 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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change the rules now - we need the truth - who are you to decide that some
people need information before other people?
Michael L. Cyr
Senior Product Marketing Manager
PC Connection, Inc.
Rte 101A, 730 Milford Road
Merrimack, NH 03055
603-423-2103
mcyr@pcconnection.com
Author: at Internet
Date: 04/21/2000 8:12 AM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD: FILE NO. S7-31-99
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This regulation should be passed to allow every one the same information at
the same. No one is above everyone else.
JOHN H. DART
220 CLIFFVIEW DR.
GREEN BAY, WI. 54302
Author: Ron Davis at Internet
Date: 04/21/2000 10:23 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File #S7-31-99
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Dear Gentlemen/Gentlewomen,
If I am smart enough to (be allowed) to elect the leaders of this
country (or so it says in the Constitution), what makes you think that I
can't manage my own seven (7) figure portfolio - given that all of the
information available to make intelligent decisions is made available to
me too?
Ron Davis
Placet@mercuryin.es
Author: at Internet
Date: 04/21/2000 7:12 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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This rule should absolutely be passed. It is the only fair and intelligent
thing to do. Why should we as individual investors be stifled by the big boys
on wall street any longer? The markets were and are less volatile when the
analysts are less able to be heard. It's only when they step in that things
go awry, witness the recent drop in the markets fueled by Alan Greenspan, the
analysts and the unrelenting media. Someone should curb those voices, but
they don't.
Renata DeAngelis
Author: "Fred Dunayer" at Internet
Date: 04/21/2000 8:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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One reason that analysts want information prior the the general trading public
is so that they can have an edge over that same public. The time lag between
the moment they gain favorable or unfavorable corporate information and the time
such information is made generally available creates significant opportunities
for market manipulation. Further, there is no requirement that the information
'as intepreted' by the analysts be made generally available at ANY point in
time. For those reasons alone the rule should be approved.
Author: at Internet
Date: 04/21/2000 8:45 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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TO: SEC
I would like to add my voice to those supporting the proposed regulation to
give individuals access to the information provided brokerage firm analysts.
As an individual investor, I have learned that I, not any stockbroker, am the
person most committed to promoting my financial interests.
And in fact, I am an analyst - by profession in another field - and as
capable of evaluating information as an analyst employed by a brokerage firm.
The idea of restricted access to informationis an old idea - one of the most
important impacts of the Internet is the greatly expanded access to
information. I used to cultivate congressional staffers to get the latest
versions of bills being marked up in committees. That information is now
available on-line - as it should be. Ditto for the information about
publicly-traded companies.
Thank you for the opportunity to comment.
Pat Dusenbury
528 Oakland Avenue
Atlanta, GA 30312
404/577-9292
Author: "MarceloEcheverria" at Internet
Date: 04/21/2000 7:57 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC:
I have read about this proposed regulation and would like to make my
thoughts known, with the hope that you will implement the regulation.
I am a 32-year-old college graduate who is hard-working and likes to invest
for my wife's and my future (and kids, if we have them). I enjoy making the
decisions on how to invest (along with my wife), and I invest for the
long-term. Having more information at my disposal, in a more timely manner,
and without bias, would be a valuable aid. Of course, analysts' views on the
information is also very important, and I would surely continue to use it;
but I am technically and scientifically inclined, and I like to have all the
facts in front of me, along with various opinions, so I can make the best
judgment. I feel this is very important to me, and I am writing this message
to you, despite the fact that time is the one thing I have the least of. I
work 24-7 in the imaging industry, and I have taken the time to write this
short message with the hope that it will help to sway the vote towards
implementation of the rule.
I wish I could discuss this further, but I must go now (time is money). If
you need anything from me, you can contact me at the following:
e-mail: marceloeche@hotmail.com
Home Tel: (954) 436-4993
Work Tel: (305) 594-3396
Thank you for your consideration of my opinion.
Best Regards,
Marcelo Echeverria
Author: Jim Fields at Internet
Date: 04/21/2000 5:53 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD won't harm analysts
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Dear Sirs,
A full disclosure of tax law has not harmed my tax accountant, nor
has a full disclosure of medical procedure harmed my doctor.
I look forward to a time when public companies have incentive to
fully disclose as much information as possible, including contact
with equity analysts. Analysts who truly add value to this information
stream will continue to prosper.
Sincerely,
James Fields
San Luis Obispo, CA
Author: David Friz at Internet
Date: 04/21/2000 12:29 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. 57-31-99
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As an individual investor, I would encourage the SEC to adopt the
proposed regulation. It is clear this regulation will only help
indivduals overcome currently unfair advantages that large firms enjoy.
David Friz
Author: m&v at Internet
Date: 04/21/2000 7:12 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the elimination of the selective disclosure rule for public
companies. Please pass a rule to allow the general public the right to hear
corporate material information as brokers and other financial organizations
do.
Mark Gos
Author: Steve Grocott at Internet
Date: 04/21/2000 12:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD
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After listening to "the experts" to whom the confidential information is
given, it doesn't seem as if many of them possess any financial acuity
beyond mine or the public's in general. I'm surprised that the selective
disclosure of crucial information isn't branded as insider trading.
Don't I, as an individual investor have a right to the same information
as any other stockholder in a company, at the same time? I do not feel
the need for a broker to help me manage my finances, especially when
more often than not the broker is going to weigh my portfolio heavily in
stocks that his or her brokerage firm are currently underwriting.
Securities analysts are going to have to get better at what they do. The
trading of securities over the internet is leveling the playing field,
in the interests of the consumer.
I have a right to buy stocks according to my own calculation of their
value. I strongly believe that I also have a right to the same
information disclosed by a publicly traded company as anyone else does
at the same time - broker or not.
Do these analysts who think that we are too stupid to pick stocks also
think that we are too stupid to see what their real interest is in
keeping limited disclosure?
The general public is already at enough of a disavantage due to "whisper
numbers", no access to IPO's, and no representation at the luncheons and
old-boy meetings that provide the Wall Street elite their outrageous
fortunes. Let's not have the SEC continue to legitimize the cheating by
allowing selective disclosure.
Steve Grocott
Independent Consultant and Independent Investor
Author: Jackie Hair at Internet
Date: 04/22/2000 8:26 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Proposed Regulation FD: File No. S7-31-99
Bruce Hair
Eagle Aircraft Pty Ltd
Author: Steve Hardy at Internet
Date: 04/21/2000 7:49 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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Get real! Limiting access to information on publicly traded companies to a
select group of "analysts" smacks of cronyism and benfits only the
"analysts." Their opposition to this leveling of the playing field arises
from recognition that their only value in the marketplace--access to
information unavailable to others--will be wiped out by this ruling. They
will be forced to find another niche in which to compete. Don't
worry--they will survive. And the market inefficiency from which they
derive their incomes today will be eliminated and the public will be the
beneficiary.
Do the right thing. Open access to information to everyone.
Author: "Hill; Jennifer A" at Internet
Date: 04/21/2000 7:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom It May Concern
I have read the propsed regulation and feel that it would benefit the
investing community. Individual investors, whether holding their accounts
through full-service brokerage firms or online services, still do research
on the companies in which they invest. In order to make an informed
decision, the user of financial information should have all the relevant and
reliable information necessary to make an informed decision. By holding
back some of this information, the companies are doing a disservice the
their investors and the public. Proposed regulation FD: File No. S7-31-99
should be put into effect.
Thank you,
Jennifer Hill
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Author: "Michael" at Internet
Date: 04/21/2000 8:54 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD, File no. S7 31-99
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The Securities Industry Association, in its comments on the proposed regulation,
assumes I am an idiot. I am insulted. I and many active investors do not need
analysts to act as filters between companies in which we are part owners and
ourselves. Maybe the SIA also thinks we should have a king to provide guidance
to us. The SIA has an elitist and anti-democratic point of view. It is highly
offensive.
L. Michael Hinds, CEO
CELL USA Inc
Author: "Paul Hogan" at Internet
Date: 04/21/2000 8:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As a private investor I find it insulting to hear that I need the help of Wall
Street Analysts to tell me where to spend my money. Why do analysts get
information before the average investor. There is no reason companies should
not make information public to the people they are soliciting to fund their
companies. By giving select individuals access to information before others,
does this not skew the market? There is no way these individuals have my
interests at heart. Analysts will promote, whether intentionally or not, their
agenda and their companies agenda and their analysis will be based on their
thoughts about what is important. I don't need someone to tell me why a company
is a strong buy today and a sell tomorrow based on their analysis. Analysts, in
my opinion, contribute heavily to the volatility of the market.
I would like the opportunity to make my own analysis (which I already do). This
does not seem unreasonable. Everyone should get access to company information
at the same time . Thanks, but no thanks to the Securities Industry Agency for
their concern (glad to see a lobby who cares). Note the extreme sarcasm in my
last statement.
Thank you,
Paul Hogan
Private Investor
Author: at Internet
Date: 04/21/2000 8:04 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed rule FD comments.
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Dear Ladies and Gentlemen,
I have just completed reading the April 20, 2000 article in "Fool on the
Hill" by Bill Barker concerning whether or not company published information
ought to be released to the public simultaneously to any other person or
body.
Without a lot of discussion, let me assure you that I prefer to have the
information immediately. I believe analysts and others have a great deal to
offer the investing community by their contacts, phone discussions, and
knowledge of where to look for other information. However, they can still
do this with simultaneous transmission of corporate information. If they
truly have something of value to add, it will be appreciated by the public
and their employer.
The current agrument reminds me of ancient high priests who forbid the people
to learn to read and write.... else they be empowered to think for
themselves. We did the same thing in this country 150 years ago with a
segment of our population. A person was endanger of bringing down the wrath
of his neighbors if he taught his slaves to read and write. We tried to
also at one time deny certain rights to women in this country. None of
these pursuits has any ligitimate purpose when exposed to the light of day.
I trust you all to do the correct thing.
Sincerely,
Alan E. Hoover
Ph. D.
Author: at Internet
Date: 04/21/2000 7:50 AM
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TO: RULE-COMMENTS at 03SEC
Subject: File No S7-31-99
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Sirs,
I fully support this proposed ruling as I think it only appropriate that
individual investors should have equal access to company information as
analysts do.
Regards,
Brian James
Author: at Internet
Date: 04/21/2000 8:17 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Carol Jenkins
Clarks Summit, Pa.
Author: at Internet
Date: 04/21/2000 7:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern,
I would briefly like to acknowledge my support for Regulation FD.
I would spend more time providing the exact reasons, but as an individual,
amateur- investor, pouring over data related to my investments, I have little
time to spend formulating a strategic counterpoint to the large lobbing groups
objections to this Regulation.
Regards
Richard A. Jervey
Author: "jimmie97" at Internet
Date: 04/21/2000 6:41 PM
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TO: RULE-COMMENTS at 03SEC
Subject: the ruling
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yes this information should go public , and open house open is safe house
for the general public .
In time like these the public need all the information it can get to make a
decision about its money.
Author: "Richard Karpay" at Internet
Date: 04/21/2000 7:53 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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The job that analysts actually perform is SELLING. TAKING ORDERS for their
company. The analyst's recommendations perform below the average of the market.
Millions of investors do pore over prospectuses (or in the modern alternative
check it out on the web), and they also compare notes (on web based discussion
boards). If these things did not take place, buying stocks would be pure
gambling. If you really believe that any of the analysts are 'right', then all
the rest are 'wrong', and with the majority being wrong, who needs them?
Analysts make the market more volatile by sending out messages that a company is
no longer a buy or whatever but has changed to something else. Really, the
company doesn't usually change drastically overnight, only the analysts reports
change. The analyst creates volatility, which makes more orders to take
(exactly their best interests - selling/buying).
Analysts don't spend much time at all ferreting out negative information about
companies. Just look at analyst recommendations and see how many
recommendations are out there to SELL. Insignificant. They don't do it. Unless
you consider the HOLD recommendation to be a sell, which means they also LIE,
are not to be trusted, and should not be given access to information others
don't have, as they lie about it.
The definition of a PUBLIC COMPANY is in PUBLIC. The information should be
given in PUBLIC, not to a private few. If only given to the few private
friends, this is a private company and should be delisted from the stock
exchange. Isn't this what is often called trading on insider information? This
is to be eliminated.
Wake up - we are e in the new millenium and many investors are actually educated
Author: Mark Kingma at Internet
Date: 04/21/2000 6:50 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I think all company information should be made availible to all people.
If certain analysts are the only ones to get some information that gives
them to much power over my portfolio. If I want to make a trade then I
want to decide which company based on the research that I can do. I
don't want to have to rely on someone elses work. They may have another
reason for wanting me to make that investment.
Let's keep this a level playing field for all. That's the American way,
to let everyone have an equal oppertunity to be unequal.
Mark Kingma
Author: "Michael Kinzlmaier" at Internet
Date: 04/21/2000 8:33 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I don't think it is fair for companies to discreetly disclose important
information to Wall Street analysts without also giving that information to
the public at large. I therefore support Proposed Regulation FD: File No.
S7-31-99.
Michael Kinzlmaier
Author: at Internet
Date: 04/21/2000 8:45 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulations FD: S7-31-99
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To The SEC:
Disclosure of vital corporate information should not be restricted to
industry analysts. The burgeoning public interest in stock market investing
needs no "filters or interpreters." Thanks to the great educational,
research and informational sharing strengths of the internet, the public is
becoming well educated on its own.
To make better investing decisions, investors vitally more incisive
information from the companies themselves. Industry analysts will still carry
a "big stick" with corporations as their services will continue to be used by
the "large block" purchasers of stock such as mutual funds, pension plans,
brokerage firms, trusts and other financial institutions.
One of the SEC's main responsibilities is to ensure that critical
information is distributed fairly to ALL investors. Please pass this
regulation.
Charles Lesko Jr., CFP
Lesko Financial Services, Inc.
Author: "Betty and Bill" at Internet
Date: 04/21/2000 7:23 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Dear Sir/Madam,
While I agree that financial analysts play an important role in the financial
markets as they exist today, I fail to see how this role will be compromised by
opening up information to everyone that was previously only available to them.
In fact, it seems to me that by providing all corporate information to the
public, it not only makes it a level playing field, but, it makes the roles of
financial analysts more competitive. Only the strong ones will survive.
It seems to me, more competition will make it much more difficult for reporting
companies to hide negative information inside their financial reports.
In a country where the government owns no copyright on its own information, I am
quite surprised that information is being withheld from the public in the
interests of the safety of the public. The public would be much safer if this
information were in the public domain.
Yours truly,
W.H. Lidington
Author: "J.R. Link" at Internet
Date: 04/21/2000 5:58 AM
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TO: RULE-COMMENTS at 03SEC
CC: "Link John R." at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the Proposed Regulation FD: File No. S7-31-99. I believe that that
companies should 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.
Thank you.
John R. Link
48017 Starlite Ct.
Fremont, CA 94539
JLink@Home.com
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"We fear things in proportion to our ignorance of them."
- Livy, Roman historian (64 B.C.-17 A.D.)
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Author: "Alan Luber" at Internet
Date: 04/21/2000 8:27 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an informed individual investor, I would like to be more informed -- as
informed as analysts who are currently privy to information in advance of us
individual investors.
In my opinion, individual investors are not playing on a level playing field.
The information that analysts have in advance of individual invests allows them
to manipulate markets to their advantage. I have personally watched analysts
declare a stock to be overvalued in order to engender panic selling so that they
can buy up shares at bargain prices. I have observed analysts declare a stock
to
be undervalued after buying up such shares in order to pump the price back up.
Analyst's ability to manipulate the markets in this matter would be reduced if
we, the public, had access to the same information at the same time.
As an informed individual investor, I take advantage of all of the information
that is available to me. I call into conference calls, I go to annual meetings,
and I communicate with investor relations at the companies in which I invest.
But I need more information, and I need it in a TIMELY manner so that I can
invest on a level playing field.
Attempts to keep analysts better informed than the general public are unfair and
perhaps unconstitutional.
Sincerely,
Alan Luber
Author: at Internet
Date: 04/21/2000 8:24 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC,
In reviewing information about proposed regulation FD: File No. S7-31-99, it
does not seem right to me that one group of people should have unequal access
to information that should be in the public areana. Since publicly traded
companies participate in a public market, it seems that the public in its
entirety should have access to all available information. Please review all
of the arguements around the Freedom of Information Act. Most are relevant to
this discussion and thus far that Act has only benefited American society and
commerce.
Thanks for your time and effort in seeking to protect me as an indivdual
investor. I appreciate being able to access all information when I am
deciding how to invest in the American marketplace.
Frederick T MacIntyre
Taylorstown VA
Author: "hugen" at Internet
Date: 04/21/2000 8:46 AM
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TO: RULE-COMMENTS at 03SEC
CC: "Ginger Carter" at Internet
Subject: Support of Fair Disclosure (FD) Regulation
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SEC:
I would like to register my support of the proposed Fair Disclosure (FD)
regulation.
The investing public is becoming increasingly aware of the many rules and
regulations designed to give NASDAQ "market makers" and the full "service"
brokers unfair advantage against us. Passing a strong version of the FD
regulation would be a step towards rectifying this long standing injustice.
Sincerely,
Philip Marks, investor
http://www.sec.gov/rules/0421b01.htm
