Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Rich & Jan Agnew" at Internet
Date: 04/21/2000 8:57 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File no. S7-31-99
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Current information available to Wall Street analysts and not to individual
investors is absurd. It's like our having to particapate in a rigged game
causing knee jerk reactions because of what we don't have access to. THIS IS
BULL.
Would you like to buy something like software or a car and not know that the
company you bought it from is going belly up next week. But an anylist decided
that you are not smart enough to know that.
Richard Agnew
Author: Danny Anthony at Internet
Date: 04/21/2000 11:04 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I absolutely believe that all prospective investors should get
information at the same time. A handfull of analysts getting
priveledged information up front is no better than insider trading!
Danny C. Anthony, Private Investor.
Author: Jeff Bauer at Internet
Date: 04/21/2000 10:34 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:
When I first saw the SIA's response to this
proposal, I thought it must have been a form of
satire. I could not believe how outrageous
their position would be. To assume that an
analyst should be given priority access to
information ahead of the shareholders (owners)
is an affront to anyone's sense of fair
play.
Please consider how self-serving the SIA's
response, and how unacceptable their position
is to the idea of equal treatment for all
shareholders.
Thank you for your time and consideration
in this matter.
Jeff Bauer
Author: "The Berteau Family" at Internet
Date: 04/21/2000 10:45 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am in complete support of Proposed Regulation FD. The current practice of
selective disclosure provides an unfair advantage to the self-serving financial
services industry. The financial industry should not be allowed to maintain its
privileged intermediary status by retaining an information monopoly when in fact
that status should be earned by providing value-added analysis on top of a level
public information playing field.
The public response of the Securities Industry Association (SIA) to Proposed
Regulation FD is both predictable and laughable. The assertion that "It hardly
needs saying that analysts perform a necessary and very valuable function in the
U.S. capital market." is at best refutable and at worst ludicrous from the
perspective of the many individual investors who operate independently of the
analyst community. The SIA's follow-on assertion that this function will be
hampered by full, open, non-selective disclosure of information because of the
fact that analysts will somehow assume a collectivist response ironically only
serves to highlight the fact that the information being selectively disclosed
does provide an unfair advantage to the recipients.
The SIA draws a parallel between the presumed impact of Proposed Regulation FD
and Presidential news conferences, claiming that the structured nature of these
conferences impedes the open flow of information. Can one really conclude,
based on the information circulated during the current administration and recent
administrations, that the formality of Presidential news conferences prevents
tenacious investigative reporters from providing unique value to their company
(and, ultimately, their subscriber or viewer base)? Clearly not -- the
conferences merely create a level playing field on top of which extraordinary
work is required to provide unique (value-added) news. It is my assertion that
Proposed Regulation FD would have the same result, removing the inherent
advantage that analysts enjoy from their current information monopoly and
forcing them to establish this advantage by dint of their own labor.
The public has no need to be "protected" from public information. I'm sure that
many Americans would be surprised to discover that fair and open disclosure
direct to the public is not already provided for. The current regulatory regime
amounts to a direct subsidy of the financial services industry, and should be
changed. Please adopt Proposed Regulation FD.
Sincerely...
Charles Berteau
3724 Stockport Drive
Plano, TX 75025
Author: Jonathan Beskin at Internet
Date: 04/21/2000 11:52 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Mr. Katz,
I advocate the acceptance of the Proposed Regulation FD.
I must also say that I am rather concerned about the sentiments of the
comments within the Ad Hoc Working Group on Proposed Regulation FD and the
SIA. The comments strike me as more of a defense of the analyst's
priviledged position than a true attack on the proposal for full disclosure.
I, for one, worry more about the spin of the analyst than I do about the
spin of the company. I have yet to be convinced that the analysts are more
concerned about providing me with accurate and expert information than they
are with making money off of my ignorance. If analysts provide a valuable
service by analyzing, understanding, and estimating information, this value
will be recognized by the individual investor and duly rewarded. I will
gladly pay for expert advise based on information that I may double-check
and compare to my own conclusions.
Jonathan Beskin
The comments represented in this email are my own and have no relationship
to my employer. All liability, responsibility, and origination is mine.
Author: "Andrew Blaher" at Internet
Date: 04/21/2000 8:32 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 believe the subject regulation is long overdue particularly in view of the
capabilities provided through the use of on-line trading. In my 20 years of
trading I have seen first hand the impact of information disclosed to
selected analysts on a stocks price. Fortunately or unfortunately, in the
past 4 years I have been following the market much more closely than I was
able to in the past. I would challenge you to look at any significant
analyst assessment based on privileged company information, and compare it
to the value of the affected security, before the information was divulged
to the general public and after and not see a trending security price.
There is no doubt that this practice serves not only the firms of the
analysts but their privileged clients as well. While I can certainly
appreciate the potential difficulty in determining when information is
relevant and what isn't, I don't see that as sufficient reason to not make
an attempt preclude such abuse. I certainly don't believe that I need an
analysts translation of the information before I can make an intelligent
decision regarding its merit nor do I feel that trickling this information
into the marketplace reduces the volatility in the market.
It is apparent that Americans are enjoying greater access to the securities
market than ever before. I believe it is time the rules of engagement are
adjusted to reflect this new reality and the medium through which it is
happening. I hope you will take the appropriate action to implement this
change at the earliest opportunity.
Sincerely,
J. Andrew Blaher
4387 Taft Ct.
Woodbridge VA 22193
Author: "Braun; Jim" at Internet
Date: 04/21/2000 11:55 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File Number 57-31-99
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You've got to be kidding! The notion that Wall Street analysts are a
protected class with respect to investment information is laughable on the
face of it. This is the same group that asserted they would never provide
on-line trading to their customers because it wasn't good for them, and then
turned right around and did because it was good (necessary) for their own
business.
If the public policy goal is to serve the investor, then separate research
firms from trading or brokerage firms. The major activity that analysts
provoke in today's world is not thoughtful investing but speculative
trading. Such activity accelerates volatility and adds terrible cumulative
transaction taxes to investment results. In the meantime, push forward for
open disclosure and, at a minimum, require any and all investor conference
calls to be open to the public on the internet.
Author: Ben Bryant at Internet
Date: 04/21/2000 11:42 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Public Disclosure
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I, like many free citizens of the U.S., have been managing my own
investments for the last three and a half years. I was aware when I began
that I knew nothing about the market but since my financial future was on
the line I made it my business to learn. I've read about a dozen books
(and continue to do so), studied information at such web sites as
"SmartMoney.com" and in general soaked up all the information I can "lay
my hands on". Investing in stocks is not "rocket science" nor does it
require an advanced degree in economic studies. It requires the ability
to read, listen and learn. Making complete information about publicly
traded companies available to us all is not only correct but it is your
duty to the taxpayers who pay your salary. The consequences of what we do
with the information are our responsibility as free people who are brave
enough to make our own financial decisions.
Yours truly,
Ben Bryant
New York City
Author: Jim Copeland at Internet
Date: 04/21/2000 8:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Ladies and Gentlemen:
I support the establishment of the above rule. It should have been
imposed decades
ago.
Thank you.
Jim Copeland
Copeland Development Company
Author: "Dominic Crapuchettes" at Internet
Date: 04/21/2000 11:35 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 representative,
I have learned that you will listen to comments from the public up until
April 28th so I am writing to voice my opinion. Yes, my involvement is due
to information I have received through articles on Fools.com. If you think
this mitigates my opinions then by all means, take this into account.
The foundation of the SIA report is stated in the first few sentences; "We
believe in the maximum flow of information from issuers... " This is a nice
sounding catch phrase which most Americans would agree should be used as a
first principle from which to begin this discussion. I am one of these
people. I too believe that the free flow of information leads to a market
with fewer inefficiencies. The discussion, then, is about how to achieve
the best flow of information. How ironic that the end result of the SIA
argument states that information flows quickest when it is withheld from the
public. A strange position to hold but one whose particulars deserve some
attention. I only have time to look at one aspect which jumps out at me.
Here is a short passage which creates many problems for me:
"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 reputational 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."
Under my current understanding, leveling the playing field for analysts is
synonymous to creating fewer market inefficiencies because it means that all
paid analysts as well as private analysts (in other words, that portion of
the public that is interested enough to follow these affairs) receive
information at the same time. Leveling the playing field means removing a
monopoly that has been created through legislation and allowing greater
competition. It does not mean that diligent work and analysis will not get
rewarded. Diligence and hard work will still get rewarded as it always has.
It means the market will be more efficient and that the huge amounts of money
that can currently be made by analysts who exploit the inefficiencies will be
diffused to the greater public. In other words, I am assuming that "the
analysts who get to the market "firstest" with the "mostest" reaps financial
rewards because of market inefficiencies. If this is not the case, then I am
unsure of how the vast amounts of money are being generated. Furthermore,
what kind of person writes about the "firstest" with the "mostest"? Not
someone I want to give much intellectual credence to. I think these ideas
are strongly biased towards maintaining market inefficiencies which can be
taken advantage of by these analysts.
Thank you for your time,
Dominic Crapuchettes
BoxerLearning (education internet company)
Author: "Denison; James E" at Internet
Date: 04/21/2000 11:31 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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The proposed regulation seems to be the only way fair investing can be done.
The current system seems to be the ultimate example of insider trading. A
few people are given information that could have a major impact on the value
of a stock. To give this only to a few people is entirely unfair. I
strongly urge you to adopt the current rule.
All information must be made to all levels of investors at the same time.
While I may have only a small amount of money to invest my dollars must have
the same right to profit as an institutional investors.
James Denison
Author: at Internet
Date: 04/21/2000 11:58 AM
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TO: RULE-COMMENTS at 03SEC
CC: TMFMax@aol.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To the SEC,
It is critically important that individual owners of publicly traded
companies (i.e. shareholders) have access to all public company information.
This statement is undeniable. Equal access to public information is a
foundation of free and fair capital markets.
It is illogical to argue that equal access should mean only _eventual_
access. When only a limited subset of investors are updated with soon to be
made public information, those unaware of this new information will behave
irrationally through their ignorance. It is clear that during this period the
market will be inefficient.
The Securities and Exchange Commission should work to maximize marketplace
efficiency.
I support the proposed rule change by the SEC regarding the fair
disclosure of information by publicly traded companies to the public. As
information is transformed from private to public, it must be able to be
simultaneously and equally accessed by individual investors and professional
analysts. Publicly traded companies should be prohibited from engaging in the
practice of discreetly disclosing important information to Wall Street
analysts without also giving that information to the public at large.
Sincerely,
J. Theodore Dodge Jr. M.D.
Yakima WA
Author: at Internet
Date: 04/21/2000 11:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please let the public decide for ourselves what is important information.
Stop allowing lobbyists dictate to us.
Dawn Douglas
Author: James D Ehlers at Internet
Date: 04/21/2000 11:40 AM
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TO: RULE-COMMENTS at 03SEC
Subject: S7-31-99
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Yes, definately in favor.
Author: at Internet
Date: 04/21/2000 11:41 AM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD: FILE NO. 57-31-99
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I wish to voice my opinion in favor of Regulation FD.
I invest on my own. I do my own research. Much of my research is in track
with that of the "analysts'" research. Much of my research is very different.
Most of the time when my own research conclusions conflict with the general
conclusions of the analysts, I base my investing decisions on my own
conclusions and compare the results with those of the "professionals." Only
one time would have been better off by going with the "professional
conclusions and reccomendations." And that one time only by less than one
percent. I am not a brilliant person or a math/numbers wiz. I am average. The
average person does not invest blindly and pays very close attention to their
money. The average person deserves the same opportunity as "pro's" get.
Clay Fauth
Laidlaw Education Services
Author: at Internet
Date: 04/21/2000 11:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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This is written to encourage the Securities and Exchange Commission to
approve the above referenced Proposed Regulation FD. I am an individual
investor who believes the established practice regarding disclosure of
information is unfair to me. While a small group of Wall Street
professionals receive critical company information privately, giving them the
opportunity to act on it long before anyone else, I must wait until these
insiders decide I am ready for the same information that is making them a
fortune while I play catch up. Let me say again how unfair this practice is.
In addition to the blatant unfairness, I am insulted by the precocious
attitude being displayed by the insiders that I am not intelligent enough to
analyze company information without their help. While I may not have a
degree in business or finance I do have a Masters degree from Emory
University in Atlanta. I assure you my intelligence has never been
questioned by anyone.
I am trying to see things from the insiders' point of view. I imagine that,
if the proposal is passed, their profit margins will decrease somewhat. I
also imagine that the current profit margins of the professionals are
sufficiently large as to allow a small decrease without causing any financial
hardship. My summation, then, is that the opposition of the Wall Street
insiders is based primarily on greed and resistance to change. Neither of
these seems sufficient cause to defeat the proposed regulation. I therefore
restate my support for the approval of Proposed Regulation FD: S7-31-99.
Thank you for the opportunity to participate in the public debate surrounding
this issue. If possible, I would appreciate a reply either by email or
conventional mail.
Sincerely,
Andy Gartman
405 Fontainebleau Dr. E.
Mobile, AL 36606
Author: dirk hanson at Internet
Date: 04/21/2000 10:58 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:
It is hard to read the self-serving analyst's rationale
for opposing this measure without cracking a smile. As
a journalist and a small investor, it has always been my
belief that the more information one has, the better
decisions one will make. The market is not well served
when a select cadre of analysts is allowed to know more
about public companies than the rest of us.
The proposed rule is an outstanding step forward for
small investors. Please support it.
Sincerely,
Dirk Hanson
Author: at Internet
Date: 04/21/2000 11:58 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 object strongly to the profitable use of material non-public information by
sell-side equity analysts. In essence, the analysis process as practiced
today constitutes insider trading. Please discharge the public
responsibility entrusted to you by leveling the playing field for all
participants in our capital market.
Contrary to the rhetoric of the SIA, reams of empirical evidence have
demonstrated that sell-side analysts fail to downgrade the issues they cover
in a timely fashion, and almost never recommend selling. Do they increase
the efficiency of the market? Hardly. They cannot offer objective analysis
because of the inherent conflict of interests between the underwriting and
analysis functions of the bank, and because their privileged access to
management depends upon cozy relationships.
Empirical evidence also shows that new information offered by analysts gets
incorporated into the price before widespread public dissemination of that
information. How, you ask? The answer is obvious. Analysts work for banks
that sell PROPRIETARY research. Banks trade on behalf of their institutional
and private clients before releasing information to the public at large. Not
surprisingly, they also profitably trade house accounts long before any of the
research generated by their analysts reaches the public at large. The SEC is
incapable of policing this activity, naturally. But studies of price behavior
and execution activity at the largest brokerages demonstrate that insider
information is frequently abused.
Let us divulge the unarticulated truth that we have all known for decades.
The material information that analysts possess, as a result of their
privileged access to management, is "non-public" in the both the spirit and
original intent of insider trading legislation. Privileged clients have
first access to the privileged information. Dissemination of such
information is sufficiently retarded as to make it non-public in every
practical respect.
Please proscribe this illegal hangover from the robber-baron days of Wall
Street so that our capital markets may continue to be the envy of the world.
If analysts want to maintain a privileged relationship with management, then
the price of that privilege must be the free, timely public release of their
complete research. Stop the proprietary exploitation of information that
should be public.
Sincerely,
Andrew Higley
2 Pomander Walk, NW
Washington, DC 20007
Author: Terrance Hodgins at Internet
Date: 04/21/2000 9:00 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear People,
I am opposed to any rules that give special
information or special privileges to any small
select group of insiders or "advisors" or
"analysts".
We have seen, over the entire history of the
stock market, that restricted insider information and
insider trading lead to abuses and exploitation
of the public, and that is why secret insider trading
is illegal.
Specially-privileged, "for some analysts only",
insider information won't be any better.
One of the fundamental rules of the stock market
is that any investor faces all of his own risks.
If an investor looses money, the loss is 100% his,
not half his, and half his broker's loss.
Why should any investor have to face 100% of the
risks, with only 50% of the insider information about
the stock available to him?
Please level the playing field, and do not allow
special "insiders only" information dissemination
any more than you now allow special secret insider
trading.
Thank you, and have a nice day.
***********************************
* Terrance Hodgins *
* weave@seaport.net *
* Willamette Web Weavers *
* Portland, OR, USA *
* http://www.seaport.net/~weave/ *
***********************************
Author: at Internet
Date: 04/21/2000 11:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am in favor of the proposed regulation. It is only common sense and
fairness that the public and analysts receive the same information from
public companies.
Rodney L. Hubbard
10830 N. Central Expressway, Suite 225
Dallas, Texas 75231
Author: hutsonw@aafes.com (Will Hutson) at Internet
Date: 04/21/2000 11:07 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I support this rule. As an individual investor, I rely on the most
accurate, up-to-date, and non-diluted information I can acquire. I don't
need an "analyst" who I don't know telling me what they think about
markets. That's why God gave me a brain. I make my decisions. Please,
enact this regulation.
Thank you,
Will Hutson
1930 Warren Road
Lorena TX 76655
Author: at Internet
Date: 04/21/2000 11:56 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 Comment Committee:
Regarding the above referenced Regulation Proposal: File
S7-31-99, please record my comment in favor of the change. The general
public has a right to the same information as the analysts. Rather than
making the work of the analyst irrelevant, this legislation is likely to make
"professional" advice even better, since there will be more open
communication between the "advisor" and "advisee." With more people having
access to more knowledge, the market will be better off.
D. E. Jukes
145 Walnut Strand
Imperial, PA 15126
Author: at Internet
Date: 04/21/2000 11:38 AM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed Reg. FD: File s7-31-99
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In this time of the growth of information available to the world, I feel
that it is incumbent upon the SEC to promote the flow of information.
Therefore, I strongly support the above proposed federal regulation. The
government should support the consumer's "right to know" and reject the
security industry desire to restrict information to a privileged few.
Jo Ann R Kingdon
Author: at Internet
Date: 04/21/2000 11:43 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I think all investors,big or small,are entitled to the same infomation at the
same time from public companies. Passage of this regulation would give all
investors an equal chance to study company statements for themselves and make
their own decisions in a timely manner rather than rely on second hand
infomation from brokers and others!!! I have been an investor for twenty years
and think this regulation will be good for all.
Charles R Knudson
CKnu101762@aol.com
Author: "Kolmus; Tessa" at Internet
Date: 04/21/2000 11:39 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 like to express my support for this Proposed Regulation. Quite frankly, I
don't understand why it is not common practice to disclose information to
any investor at the same time already.
Tessa Kolmus
Fairfax, VA
Author: "A. Larson" at Internet
Date: 04/21/2000 10:41 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/Madams:
I feel that the current restriction of information to the public
investor only serves the large investment firms and their larger
clients. It allows them to make educated trades before the general
public. This insures their success and allows them to make more off the
poor, uninformed investor. By the time important information is leaked
out to the average investor, the "insiders" have already driven the
stock price up or down and it is too late. By this time the average
investor has already lost his money or must buy at a much higher price.
The argument that the current method stabilizes the market has been
proved wrong by the fact that the Market just had it's greatest single
day drop on April 7th, 2000. What really happens is that the analysts
"bail out" before everyone else and any "panic selling" still occurs,
after the analysts with insider information have covered there bigger
cleints.
This is where the term: "buy on rumor, sell on fact" comes from. What
this really means is the analyst have allready informed the large
investment firms of whats going on and the significant moves have
already been made.
I support any regulation that allows for a more level playing field and
that seems to be the goal of Proposed Regulation FD: File No. S7-31-99.
Thank You:
Arthur Larson
alarson@larsonusa.com
Author: "Todd M. Maceira" at Internet
Date: 04/21/2000 11:49 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To the SEC,
I do not believe analysts provide a relevant service to millions of
Americans, at least one that merits special status w/regards to information.
As a private investor, many others and I deserve a fair playing field for
our investments.
The special status analysts receive, directly benefit their company's larger
business clients, and in turn are detrimental to smaller investors.
Information is the most valuable asset for an investor.
The timing of an investment is the most important decision an investor will
make
The market has been extremely volatile over the last three years, exactly
what have analysts done to stabilize the market?
Sincerely,
Todd M Maceira
Maceira@mindspring.com
United International Supplies
Author: "McElligott;Donald" at Internet
Date: 04/21/2000 12:06 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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In support of Proposed Regulation FD: File No. S7-31-99
It is clear to me that the main reason to oppose this rule would be to
protect one class of investor/analyst at the expense of others. It also
seems clear that this rule does not interfere with the "inside" analysts
ability to perform there function, it simply brings them into the full light
of the public.
Fair markets require equal access to information.
______________________
Donald McElligott
Senior Network Engineer
IDOM Inc.
* (973) 792-2219
* dmcelligott@idomusa.com
Author: mmcinnes at Internet
Date: 04/21/2000 11:59 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The SIA puts forward a self-serving and condescending view of the
financial markets and the millions of participants in these markets. It
is clear surely that analysts by and large have not acted to serve the
public interest, but rather have acted in their own self interest,
essentially serving the interests of managements and investment banks.
I applaud the SEC's efforts to make the disclosure of information to the
markets more widespread, democratic, and truly in the public interest.
I hope you will not be diverted from that purpose.
Professor Morris McInnes
Sawyer School of Management
Suffolk University
Boston, MA 02108
Author: "Dave Miller" at Internet
Date: 04/21/2000 8:41 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File No. S7-31-99
------------------------------- Message Contents
I want to add my support for the fair disclosure regulation. Individual
investors have aright to know and at the same time as the rest of the
investment community. Under any circumstances the analyst community needs
to earn their way by providing complete analysis of companies and not form
having information that no one else has. Please pass the proposed
regulation.
David Miller
Author: Paul Milligan at Internet
Date: 04/21/2000 11:59 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Analysts should not have any 'inside information' that is not made
available to the general public and media at the same moment.
While the 'old school' establishment of ' full service brokers' and
'analysts' want to maintain control and protect their positions and incomes
at our expense, based on the illusion that we need them to protect us from
ourselves, this is patently nonsense, and indeed, un-American.
As an investor, I favor this regulation. The opposition of the 'old
school' industry to it only stengthens that position.
Paul
>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~>~~
Email to pjm@pobox.com
My WWW site is at http://www.pobox.com/~pjm ,featuring free HVAC software
Never color inside the lines in the coloring book.
Color instead where it pleases you to.
You can only color a page once, but there are always more pages.
Author: "Kate Nickerson" at Internet
Date: 04/21/2000 11:40 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I understand the comment period has been extended. My comments humbly
submitted.
"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....
Balderdash! The propsed rule doesn't eliminate giving information to small
groups of analysts, just giving that same information to everyone.
"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.
Actually after watching CNBC I think analysts and the media are the primary
way to propagate mass hysteria.
Every day I watch the supposed expert analysts spew off with comments like "
Well we're not out of the dark yet we can expect some volatility coming up"
It took an MBA from Harvard to come up with that? Isn't volatility the very
nature of the market? Unless you've invested the rent money or bought on
margin, short term volatility is irrelevant. With advice like that I'm
better off on my own.
"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"
Blah blah blah. Anything management would rather not disclose, they have to
disclose and it's right there in black and white in the notes to the
financial statements, albeit in tiny print on page 348.
Most of the time the analysts comments are worthless anyway. If their firm
brought the company public do you think that if the company turns out to be
stinker they are going to tell you? No way they issue some kind of lame
rating like "accumulate" or "hold". As if we're all total morons and can't
see that total conflict of interest. Even when a company is crashing and
burning you almost never hear a blatant "Sell!" They aren't looking out for
the individual investor, they're looking out for themselves and their
commission checks.
Kate Nickerson
Individual Investor no company affiliation
Author: at Internet
Date: 04/21/2000 11:59 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hi,
I would like you to know that I support this proposed regulation. I do not
believe that companies should be allowed to discreetly disclose important
information to Wall Street analysts without also giving that information to the
public at large. I do not depend on analysts; I research companies, their
products, and their business models myself and arrive at my own interpretations.
I usually stick with companies within my industry, since I read trade
publications heavily and have a greater level of familiarity. I do not believe
it is fair for an individual investor to miss out on such information when
trying to make informed decisions.
Thank you for this opportunity to voice my opinion,
Vito
Author: aparez@fcw.com at Internet
Date: 04/21/2000 11:55 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Greetings,
This message is to show my support for Proposed Regulation FD: File No.
S7-31-99. I think it's important that the markets become ruled by
interested investors and not by analysts involved in clandestine
conversations with corporations.
Thank you.
Author: "J. Parskey" at Internet
Date: 04/21/2000 11:52 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
We need full disclosure!
Author: at Internet
Date: 04/21/2000 11:53 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sir or Madam:
I recently read about this proposed regulation and learned that it contains
language which ends the practice of public companies disclosing information
to analysts and investment companies prior to releasing it to the general
public. I am very much in favor of this provision. I would like to explain
why.
In order for markets to be efficient, all investors must have access to all
information at the same time and in the same detail. Whether or not it is
accessed, used or analyzed properly is not for Wall Street or the SEC to
decide. Small investors are already at enough of a disadvantage because they
do not have the banks of computers, investment tools and 40 hours per week to
analyze individual stocks and other investments. Thus, mutual funds have
become a favored means of investing as it eliminates the need for the
individual to be constantly vigilant and watchful over a diverse group of
companies. However, if an individual investor wants to pursue a company
because he/she believes in its products and its earnings potential, the
investor should be allowed to do this without being handcuffed by having
information filtered by analysts or its release to the public delayed for any
time. This is the essence of an efficient market.
With today's technology, namely the internet, the wide availability of
investment training available to the public and the myriad sources of free or
inexpensive financial data available to the public, it is no longer necessary
to shield the public or manipulate the flow of information in the name of
protecting market volatility and efficiency. I highly doubt that there are
enough individual investors with enough assets at their disposal that an
irrational buy or sell move on the part of these investors could create
volatility in a stock. Compared to the enormous assets available to
investment companies, mutual funds, pension funds, etc. the small investor's
portfolio is minimal. I also think that you underestimate the ability of the
average investor. I see many people today that are managing relatively large
sums of money in 401(k) accounts, IRAs, or money from bonuses and stock
options. In general, I would say that the average person is learning more
about investing every day and trying to do their best to grow their assets
and provide for their future. With this in mind, they deserve every chance
to make this happen and thus need timely access to information about their
investments just as analysts and investment companies do.
The upside to ensuring that public company data is available to everyone at
the same time and in the same detail far outweighs the risks. I respectfully
request that you consider approving the end of early disclosure to analysts
or preference to any person regarding the release of public company data.
Thank you for your time.
Sincerely,
Donald G. Pomeroy II
1209 Rosewood Court
Longview, TX 75604
dgpomeroy@aol.com
Author: Keith Reeves at Internet
Date: 04/21/2000 8:48 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am writing is support of fair disclosure of information by publicly traded
companies. This proposal would inject more fairness into the current market.
Information is vital to our economy. The current system restricts access to
that
information. Please support the measure.
Thank you.
Sincerely,
Keith Reeves, Ph.D.
Professor of Early Christian Literature
Azusa Pacific University
kreeves@apu.edu
Author: "Scott Rubel" at Internet
Date: 04/21/2000 11:11 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To Whom It May Concern:
It is with great dismay that I read the comments of April 6, 2000, by The Ad Hoc
Working Group on Proposed Regulation FD, which quite clearly came out against a
"level playing field" in which the public and analysts would have equal access
to company information.
As an individual investor I take strong issue with any group attempting to
maintain control over what should be public information, especially when their
arguments are so blatently self-serving. I have read a number of analysts'
reports, and frankly I do not believe that "analysts perform a necessary and
very valuable function in the U.S. capital market." If their work is so
valuable then they have nothing to fear from the rest of us having the same
information: the clear superiority of their analyses will continue to command a
premium. As one of the non-theoretical "millions of individual investors and
potential investors poring over prospectuses and periodic reports" I suspect
that this will not be the case however.
The Working Group is concerned that a change in policy will enable companies to
put their own spin on news which would otherwise be ferreted out by diligent
analysts. This comment, coming from institutions which regularly conceal or
spin away their own potential conflicts of interest, is hypocritical and
self-serving at best. When I buy a car I do not want someone else to test drive
it and tell my what problems it may have; I do it myself. When I buy a house I
look for full disclosure from the buyer, building inspector, et al.; I do not
pay someone else to tell me what to think of that disclosure. I expect the same
thing when I purchase shares in a company, and to tell me otherwise is
patronizing and a waste of my time. I therefore strongly encourage the SEC to
enact proposed regulation FD with all due haste.
Sincerely,
Dr. Scott Rubel
Austin, Texas
Author: Kevin Shires at Internet
Date: 04/21/2000 10:43 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I think this rule should be enacted post haste. The idea that an 'analyst'
or 'market maker' should have access to company information before it is
disclosed to the public is outrageous. While the reason for this rule is
based on some argument that it reduces market volatility because they are
more intelligent than me, it smells more like a violation of the insider
trading rules I learned in my Securities Regulation class during law school.
The very essence of a capital market is the free exchange of assets between
parties with each party making their own intelligent and informed decision
regarding those assets. How is this goal met if some 'analyst' at a
brokerage has information regarding a company that has been withheld from
the trading public? Ninety percent of all mutual funds managed by these
genuises can not beat the S & P 500, a passive index, so making an
assumption about their intelligence is a leap of faith I would prefer not to
make.
Kevin T. Shires
Author: "David J. Smith" at Internet
Date: 04/21/2000 10:50 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The SIA's comments re- the value of analysts to the Markets are specious and
mis-leading. It's true that analysts perform a service to investors - it is
NOT true that they cannot perform this service in the abscence of privileged
information. My vote is in favor of mandating that publicly traded companies
make ALL information available to ALL potential investors at the same time.
No more good 'ol boys garbage!!!
David J. Smith (an investor who takes analyst's comments with a grain of
salt)
8010 Twining Oaks Lane,
SPRING,
TX 77379.
Author: "Charles Sorrentino" at Internet
Date: 04/21/2000 11:36 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Regarding the proposed rule, It is my belief as an individual investor that
information is valuable, and until the recent upswing in personal online
investing, relevant informtion about the management practices and financial
strength of a company has been difficult to come by, other than by subscription
to comaratively expensive reports, and even then, only those reports that happen
to be available. In order for an investor to make an informed decision on a
securities purchase, it was necessary to subscribe to multiple services and
compare each, thus having to make a decision about which analyst to believe.
With the advent of the internet, there has been better access to company
information simply because the analyses have intenet market value. I view that
as a welcome change. However, the available information is still confined to a
small portion of companies in the public market. As an individual investor, it
would benefit me greatly in making better choices to have access to more
information regarding any company in which I might have an interest. For this
reason, I strongly support the proposed rule.
Charlie Sorrentino
Author: Glenn or Betty Jo Stockton at Internet
Date: 04/21/2000 11:57 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I would like to add my voice to those who believe that individual
investors are better served by being given the same information at the
same time as Wall Street "analysts", as opposed to having those
"analysts" sift through the information and tell us what they think we
need to know. It is my belief that, contrary to the statements of those
analysts, market volatility is far more likely to be caused by the
frequent "upgrades" and "downgrades" of the experts (who stand to gain
from frequent trading by their clients) than it is by individual
investors having access to the information and deciding for themselves.
I have not yet heard one single intelligent argument supporting the
continuation of the current unfair system.
Robert G. Stockton
8501 Pajaro Court
Orlando, FL 32836
Author: "Dale Temple" at Internet
Date: 04/21/2000 9:06 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD: File No. S7-31-99
------------------------------- Message Contents
To whom it may concern,
I am wholeheartedly in favor of the passage of this rule. After reading the
official response opposing this rule by the Ad Hoc Working Group on Proposed
Regulation FD and the Legal and Compliance Division of the Securities
Industry Association, I have never felt stonger than I do now. For them to
say that we are too stupid to handle this privy information infuriates and
insults me.
I say pass this rule and end the special interests of this sanctimonious
group.
Sincerely,
Dale Temple
Facilities Manager
Seattle Country Day School
(206) 284-6220, ext. 418
Author: HIGHRISE1@webtv.net (H WW) at Internet
Date: 04/21/2000 12:06 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD file#S7-31-99
------------------------------- Message Contents
I am all for this regulation as an investor
Howard Waldholz
1500 South Ocean Blvd
Pompao Beach, Fl 33062
Author: at Internet
Date: 04/21/2000 10:50 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I have read the arguments of the professional analysts telling me that I'm
not smart enough to use this additional information if it was made available
to me and I don't buy their arguments. I agree that this will take away one
of their main advantages, but that's too bad. I should have access to the
same information that they do and when they do. This is a good proposal for
the individual investor and I fully support it.
Mark Wimmer
http://www.sec.gov/rules/0421b05.htm
