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U.S. Securities and Exchange Commission

Comments on Proposed Rule:
Selective Disclosure and Insider Trading

Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99

  
Author:  "David and Jan Anglin"  at Internet
Date:    04/21/2000  4:32 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:  File No. S7-31-99
------------------------------- Message Contents 
To whom it may concern:
     
We support the new SEC rule listed above,
     
Signed,
     
Janet L. Goedeke ,
David R. Anglin

 
     
 Author:   at Internet
Date:    04/21/2000  5:38 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No S7-31-99
------------------------------- Message Contents 
Dear Sir:
     
I am writing in full support of changing SEC regulations so that full 
disclosure of information be made public to all, not just to security 
analysts.  Meaningful information often comes into the hands of analysts 
before being made public and their employers reap the benefits of this 
information buy buying/selling (and advising their clients to buy/sell) 
before the public has a chance to react.
     
In fact, I would recommend that conference calls be opened to the public on a 
listening basis only so that relevant information is available to all.  While 
a huge number of participants on conference calls makes them unwieldily, the 
ability to listen to the guidance given by companies to analysts, as well as 
the questions and responses to that guidance would level the playing field 
for all.
     
Richard Blackburn
RR 1 Box 55
Princeton, IN 47670

 Author:  "shells_rich"  at Internet
Date:    04/21/2000  4:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD:FILE NO.S7-31-99
------------------------------- Message Contents 
To whom it may concern
     
I'm writing this letter to express the fact.   There is no reason whatsoever 
that analysts should be privileged to any information prior to the public, 
this is nothing more than censorship. We are not talking about matters of 
national security here we are talking about publicly traded companies.If the 
sec is trying to do me a favor by protecting me from information, don't!!! 
favors like this don't help they hinder and produce unequal oppoturnites.why 
would analysts want it to be equal ?? they don't!!they want the info first 
(the early bird gets the worm)
I hope the SEC isn't fooled by the analyst here and the SEC makes the fair 
and equal choice to make the playing field level
Richard S.Blount II
     
     
     

 Author:   at Internet
Date:    04/21/2000  5:15 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To whom in government this should be directed:
     
I am appalled that Wall Street and government plan to conspire (yes, 
that is the correct term) to withhold or release as they see fit 
information from public companies that millions of Americans own shares 
in because they think they can better communicate said information to 
us.  Do you think the American public can't read a prospectus?  I 
frankly find reading a prospectus easier than hooking up a computer, but 
millions of Americans know how to do that, too.
     
You can't and shouldn't think you and Wall Street are securities 
sovereigns.  I urge you not to consider this legislation. Absolute power 
corrupts absolutely!
     
Kim Brewster
     

 Author:   at Internet
Date:    04/21/2000  5:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As an independant investor, I'd just like to voice my opinion on the matter of 
disclosing information to the public instead of "market analysts". First of all 
the current method obviously supports a sort of insider trading since people 
with non-public knowledge are able to use that knowledge before the public even 
has a chance to see it. Secondly I'd like to comment on the SIA's filing that 
stated:
     
"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 reputational and financial 
rewards. Leveling the playing field for analys!
!
!
ts, as among themselves and vis-a-vis the general public, will undermine the 
great advantages of the current system"
     
This is a royal load of crap. These analysts can still complete their "analysis"
of the market if the general public is privy to the information that they are. 
If "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" then the analysts can still perform that 
function for those that don't want to do if for themselves. The intelligent 
investor, on the other hand, can also choose to get the information for himself 
without having some "analyst" give him information that is only going to line 
the "analyst"'s pocket with money.
     
Surely you don't believe that people will buy these arguements that you lay on 
the table. If you're going to be a bunch of devious, conniving bastards then at 
least own up to and tell us that this system is in place to help the good ol 
boys and not those of us that actually pay for it. Don't you have better spin 
people than that?
     
     
Sincerely,
Robert Castles, Jr.
[Just some nobody investor]
     

 Author:  Janell Cole  at Internet
Date:    04/21/2000  4:44 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear SEC,
     
I am an individual investor who fully supports the new proposed 
regulation on fair disclosures.
     
I think the comments by the SIA opposing the proposed regulation are 
extremely self-serving. If they had their way, it would only serve to 
institutionalize an unfair situation.
     
Fair is fair. Please adopt the proposed rule.
     
Thank you.
     
Janell Cole
     

 Author:  fac  at Internet
Date:    04/21/2000  6:13 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Pass the rule: Proposed Regulation FD
------------------------------- Message Contents 
Dear Sirs:
     
Please pass the rule, Proposed Regulation FD, that would require, among 
other things, that companies no longer engage in the practice of discreetly 
disclosing important information to Wall Street analysts without also 
giving that information to the public at large.
     
As a user of E-Trade and the Internet, I do all of my own research and 
investing in the stock market.  I was appalled when I learned that the 
brokers and Wall-Street analysts get information that is withheld from us 
until significantly later.  They have a definite and unfair advantage, an 
advantage that is contrary to free-market exchange.  They make money 
trading on our forced ignorance.
     
Frederick A. Costello
     
Frederick A. Costello, Inc.
12864 Tewksbury Drive
Herndon, VA  22071
(703) 620-4942 (voice)
(703) 620-4134 (fax)
     

 Author:  Leigh Curry  at Internet
Date:    04/21/2000  5:34 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sirs,
     
As an investor, I am extremely displeased to see your latest response to 
the proposal that public companies must report important news to 
analysts and the general public at the same time. Where is the fairness 
in this proposal?
     
This current situation is a joke!!! I can't tell you how many times I 
have watched a stock go down all day long, with absolutely no news, just 
to find out the next day that the company had told an analyst important 
information without releasing it to the street. The way the rules 
currently stands is unfair and certainly unjust. LEVEL THE PLAYING FIELD 
NOW!
     
Leigh Curry
investor
     

 Author:  Al Dargis  at Internet
Date:    04/21/2000  6:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents 
The proposed regulation FD should be adopted by the SEC. It's adoption 
is unlikely to have much effect on the contribution of investment 
analysts.
It will help determined  people to find more easily what the unfiltered 
new facts
of a publically traded company's performance are.
     
Sincerely,
     
Al Dargis
     

 Author:  Bobby Davis  at Internet
Date:    04/21/2000  5:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD
------------------------------- Message Contents 
Please level the playing field as reguards the distribution  information 
about publicly owned businesses.    Best regards, Bobby Davis
     

 Author:   at Internet
Date:    04/21/2000  6:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
This proposed regulation would level the playing field for all investors.
     
Companies should not be allowed to inform analysts of certain information and 
then dispense the information to the public with their spin on it.
     
The majority of the investors are certainly as smart as or smarter than the 
analysts.  I certainly do not believe that analysts make the market more 
volatile.  In fact, I think the opposite is true.
     
Level the playing field.  Make this regulation "the law."
     
Sincerely,
     
     
Betty & Joe DeFloria
bdeflo@aol.com

 Author:  redbarn@cstone.net (Leonard Dreyfus) at Internet
Date:    04/21/2000  5:32 PM
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TO: RULE-COMMENTS at 03SEC
Subject: analysts and perferred access to public companies
------------------------------- Message Contents 
Do you suppose that analysts are more intelligent or ethical than individual 
investors? Why give them a perferred position? 
     

 Author:  "Chris Ducret"  at Internet
Date:    04/21/2000  3:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am voicing my support of the propose regulation FD: File No. S7-31-99.
     
The segregation of information in the equity markets are unwarranted and 
follow and "old boys club" mentality that is outdated and inaccurate.  It is 
my right as an investor to have full disclosure from a company without going 
through a middleman like an analysis to get a washed down version.
     
Please move this new regulation forward.
     
Thank you
Christopher L. Ducret
     
     

 Author:  Jon Geggatt  at Internet
Date:    04/21/2000  5:26 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: "'feedback@kennedy.senate.gov'"  at Internet
CC: "'john_kerry@kerry.senate.gov'"  at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To Whom It May Concern:
     
I have just read the SIA's response to this proposal and consider their 
statements without merit.
     
I, along with many other individual investors (their numbers are growing every 
day) are quite capable of handling news, both good and bad - and are also able 
to interpret and act upon the results accordingly.
     
I am also forwarding a copy of this message to my State Senators. I would hope 
that common sense on your part would preclude the need for political 
intervention to insure fair and equal treatment for all investors.
     
Sincerely,
     
/s/ Jonathan B. Geggatt
     
     
     

 Author:   at Internet
Date:    04/21/2000  6:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Hi,
I think: as long as there are still analysts of famous broker-companies who 
advice  a "strong buy" for stock the own company is already selling, as long 
i really would prefere to get all informations for myself as soon as 
possible. 
Best regards
Dominique Gradenwitz

 Author:   at Internet
Date:    04/21/2000  6:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To Whom It May Concern:
     
I have just read the SIA's response to this proposal, and I must say I find 
it outrageous.
     
I could do pages and paragraphs on the reasons why, but to say that certain 
analysts should have access to negative information prior to other 
shareholders (like me) is to create the same kind of unlevel playing field 
which has destroyed investor confidence in foreign markets such as Japan and 
elsewhere.
     
My money is the same as anybody else's money. In a democratic country, with 
supposed equality of position, investment and otherwise, to release relevant 
investing information to the privileged few is absolutely unacceptable. The 
idea that only an analyst asking questions in private can ferret out 
information from corporate executives *who are, by definition, required to 
serve the public investor while pursuing their private corporate agenda* is, 
on its face, absurd.
     
I am forwarding a copy of this message to my Congressman as well as to you. I 
would hope that common sense on your part would preclude the need for 
political intervention to insure fair and equal treatment for all investors.
     
Sincerely,
     
Andrew J. Halligan

 Author:   at Internet
Date:    04/21/2000  5:29 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: remona_ellis@iwhs.org at Internet
CC: Redcheck81@aol.com at Internet
CC: Jhimern@aol.com at Internet
CC: Phatd75460@aol.com at Internet
CC: Ladysun@neto.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
To Whom It May Concern:
     
I support the subject regulation. I feel that I'm qualified to decide what 
information is important to me and I should have the same opportunity to 
obtain information as the Wall Street insiders. 
     
I'm sure the financial analysts use the information to the benefit of 
themselves and the companies that pay them. I don't consider anything I read 
or hear from an analysts unbiased, therefor, I should have the same 
information available to form my own opinions.
     
Thank you for you consideration in this matter.
     
Lin Harper
Backwater Investment Club   

 Author:  "Sean Healey"  at Internet
Date:    04/21/2000  3:33 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
In light of recent market events, your statement that "...analysts 
contribute to the overall mix of information in the marketplace, greater 
accuracy of market prices, less volatility and, in general, greater 
efficiency"  seems far from the truth.  Analysts may make a contribution to 
the market but it is rarely in the best interest of the masses.
The assumptions you make seem to be based on days when the average investor 
did not have access to the amount of information readily available today. 
This information allows the average person to conduct thorough research and 
analysis of companies and make educated choices.  Limiting the information 
or "spinning" the facts would hurt those trying to make educated decisions. 
You refer to "The alternative model of millions of individual investors and 
potential investors poring over prospectuses and periodic reports..." In my 
opinion having millions of viewpoints valuing the market would ultimately be 
more efficient and accurate than allowing the relatively small number of 
analysts have such influence on valuations.
     
Sean Healey

 Author:  dhood@wfubmc.edu (David Hood) at Internet
Date:    04/21/2000  5:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sir:
  I want to comment on the above referenced proposed rule change: it is a
good rule, ending the exclusive transmission of information to selected 
"analysis's" and bypassing the individual investor. The individual should be 
given the benefit of doubt and it must be assumed that the individual 
investor with an interest in a particular company has as much likelihood of 
understanding the import of the information currently passed exclusively to 
"analysis's". As presently exercised, "analysts" and the companies, 
brokerages houses, investment banks they work for get SEC sanctioned 
exclusive information which is excluded from the individual investor.
     
  I urge you to pass this proposed change in the applicable rule.
     
     
David D. Hood
1658 South Marblehead Road
Clemmons, NC 27012-9788
     

 Author:  Sean Jennings  at Internet
Date:    04/21/2000  2:48 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sir or Madam:
     
I disagree with the SIA's filing. 
     
1) Analysts do not perform much of any function, 
because they are by and large very poor at what they 
do, and heinously biased in their opinions even if 
they are talented due to affiliations. The typical 
upshot is a glowing review of a company that the 
analyst's firm then sells out of -- this happens 
constantly, as the SEC is aware. Furthermore, 
analysts, even those with genuine talent and insight, 
focus on the short term to detriment of both 
individual and institutional investors -- this too is 
hardly a secret.
     
2) Individual investors can and do perform their own 
research. I do read the 10K's and 10Q's, I do follow 
the news and conference calls, I do try to learn from 
every source I can, direct or otherwise. Of course, I 
am denied the opportunity to do many of these things 
as soon as some of the "professionals" do, which is a 
big part of the reason I am writing this. If the 
analysts were better at what they do, and less biased, 
etc., I would feel less strongly about the issue -- 
but I would still be writing this letter.
     
3) Analysts have the power to move the market, they 
know it, and they abuse it (see 1, above). If 
volatility were to be avoided, one step in that 
direction would be to fire all the analysts.
     
I am not the only individual who feels this way, nor 
am I some crackpot daytrader, although investing is an 
important part of my life. I doubt most people, even 
those who invest for a living, are even aware of what 
is going on, and therefore they will not be writing 
in. I assure you, however, that if they were aware of 
this issue, they would write in, too, with similar 
opinions. Again: all the analysts know about this, yet 
almost none of the individual investors do. This is 
not an equitable forum for discussion, so I hope that 
my few words here will carry some of the weight of 
those whose opinions must go unvoiced.
     
Yours truly,
Sean Jennings
     

 Author:  "Richard Jessen"  at Internet
Date:    04/21/2000  4:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I support the above proposed regulation.
     
                                                         Richard Jessen
                                                         514 NW Chapel Dive
                                                         Ankeny, Iowa 50021
     

 Author:  Lisa Jones  at Internet
Date:    04/21/2000  5:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As an individual investor, I strongly support eliminating selective 
disclosure.  I put selective disclosure in the same category as insider 
trading.  It is hard to believe that one is illegal while the other is 
not.
     
Regards,
     
Lisa Jones

 Author:   at Internet
Date:    04/21/2000  6:10 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Fair disclosure of information by publicly traded companies 
------------------------------- Message Contents 
To whom it may concern:
     
This is a no-brainer.  I completely support full disclosure.
     
kabsfan

 Author:  Barry Kingsbury  at Internet
Date:    04/21/2000  5:46 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
The comments by the Ad Hoc Working Group on Proposed Regulation FD and 
the Legal and Compliance Division of the Securities Industry Association 
are both self-serving and biased.
     
For example, they have stated:
     
>    They, (the analysts) 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.
>    But it does need to be said that analysts cannot do their work nearly as 
well as they do now if they are forced to
>    do their work, at least when it comes to interaction with issuers, 
collectively -- in a pack.
>
     
This ignores the simple fact that their work is private. In a free and 
open marketplace, no one should be provided information that others do 
not have. No one is trying to restrict analysts from obtaining 
information from companies. Instead, what is being argued is that the 
information provided by companies should be provided to all, not to the 
select few. Analysts will be just as free to investigate, meet with, 
discuss companies as before. What is being changed are the private 
meetings where they are provided information that others cannot get.
     
And, if analysts cannot stand the competition from additional people 
being able to acquire this information and ask questions, then perhaps 
they don't belong in an occupation (stocks) whose whole basis is the 
open and free trading of information.
     
To deny equal access to all is to give privilege to some.
     
Sincerely,
     
Dr. Barry M. Kingsbury
4 Lincoln St.
Hopkinton, MA 01748
     

 Author:   at Internet
Date:    04/21/2000  6:30 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Alaysts/Stock
------------------------------- Message Contents 
In regards to the full disclosure regarding publicly traded stock and 
analysts,I have a rather pointed opinion. Personally I would rather do my own 
stock evaluation. Has no one noticed how erratic the "analysts" have been 
behaving lately? Many are just paid pawns (via stock) for the in question 
companies.  I believe as an individual investor that the brokerage firms 
should not have the ability to buy or sell or determine a "VALUE" before any 
other investor. My money and your is the same. This is exactly what brought 
down Japan a few years ago. Thanks for your time.
     
     
     
     
Dr. Eric Knight
Milwaukee, WI
414-453-6667

 Author:  "Liwnicz; Regina"  at Internet
Date:    04/21/2000  4:23 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
As an investor (and citizen) I am firmly in favor of the proposed change to 
the rules of disclosure by publicly traded companies. As practice of trading 
is changing and more and more small investors do their own buying and 
selling of securities, so must the rules and traditions governing the flow 
of information change to allow for equal and fair distribution of necessary 
information. Here are some of the reasons:
     
1. Wall Street is not alone, not even first, in facing change. Take the 
medical profession. The advent of web has made medical information of all 
kinds widely available. Would you be opposed to free distribution of this 
information, because regular people do not have the required academic 
preparation to understand it and act on it? Of course not. There are legions 
of doctors, pharmacists and other medical professionals to explain and 
interpret the information. As one of these professionals, let me tell you, 
the practice of medicine and the health of many has benefitted from better 
informed and more assertive patient population. 
We will still need experts to analyze and explain the financial and other 
information. The difference is we will be better prepared to ask questions 
beond those that experts may ask themself. 
     
2. Fair and free access to information ranks next to free speech as basic 
individual right. Any form of censorship, even well-meaning, carries 
potential for manipulation and misuse. The information revolution we are now 
in the midst of would have warmed the hearts of our founding fathers, who 
considered well infomed citizenry the basis of our democratic institutions. 
     
Regina G. Liwnicz
1331 Crestview Road
Redlands, California   

 Author:  Paul Luce  at Internet
Date:    04/21/2000  2:36 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I fail to understand how in this day of increasing information available to 
the public and with a fair and balanced delivery system made available, 
that the SEC can seriously consider not implementing a rule that prohibits 
secret and manipulative disclosures.
     
It is not uncommon for individual stocks to gain or lose 20% of their 
market value in a single day.  Oftentimes, the stock will be back at or 
near its original level within a week or two.  Meanwhile, some people have 
made money and others have lost money.  I truly believe that putting better 
controls on secret "leaks" of information will be better for all investors, 
perhaps eliminating the some of the wild rides the markets have recently 
had.
     
Paul A. Luce
pluce@hotcoco.infi.net
     
     
     
     

 Author:  "Christian D. Malesic"  at Internet
Date:    04/21/2000  5:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
TO: "Specter; Arlen"  at Internet
TO: "Santorum; Rick"  at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sir or Ma'am,
     
I have just read the SIA's response to this proposal, and I must say I 
find it outrageous.
     
I could do pages and paragraphs on the reasons why, but to say that 
certain analysts should have access to negative information prior to 
other shareholders (like me) is to create the same kind of unlevel 
playing field which has destroyed investor confidence in foreign 
markets such as Japan and elsewhere.
     
My money is the same as anybody else's money. In a democratic country, 
with supposed equality of postion, investment and otherwise, to 
release relevant investing information to the privileged few is 
absolutely unacceptable. The idea that only an analyst asking 
questions in private can ferret out information
from corporate executives - who are, by definition, required to serve 
the public investor while pursuing their private corporate agenda - 
is, on its face, absurd.
     
I am forwarding a copy of this message to my Senators as well as to 
you. I would hope that common sense on your part would preclude the 
need for political intervention to ensure fair and equal treatment for 
all investors.
     
 --
     
Sincerely,
     
Christian D. Malesic
President
CM Squared, Inc.
christian@cmsquared.com
     
     

 Author:  Dwight McCann  at Internet
Date:    04/22/2000  3:23 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Sirs:
     
I support Proposed Regulation FD.  The free and equal dissemination of 
all information pertaining to publicly owned entities is clearly at the 
heart of an informed capital market.  The contrary suggestions made by 
the 'Ad Hoc Working Group on Proposed Regulation FD and the Legal and 
Compliance Division of the Securities Industry Association' that 
providing access to all investors rather than self-selected analysts fly 
in the face of commonsense and fair play.  The recent extraordinary 
volatility of the market, occurring under the current rules, is prima 
facie evidence that their contentions are simply wrong:  they have not 
reduced volatility, they have not ferreted out negative information, it 
is does need saying that whatever valuable and necessary service they 
provide could equally be provided regardless of who else might be privy 
to currently restricted knowledge.  The position of the SIA is blatantly 
self-serving, littered with logical inconsistencies and in itself 
suggests they have a need for secrecy to survive.
     
This email does not represent the position of the Regents of the 
University of California and is in on way approved or supported by the 
University, it's agents, trustees or employees.  It is my personal 
opinion as an investor.
--
Dwight M. McCann
Phone: 805-893-3113
FAX:   805-571-2606
mailto:dwight@trixie.ucsb.edu
http://borg.ucsb.edu/dmm/html/startframe.html
     
     

 Author:   at Internet
Date:    04/21/2000  5:28 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:file #S7-31-99
------------------------------- Message Contents 
urge you to make information available to the public
     
Evelyn L. Michie
independent

 Author:  "Judy Petersen"  at Internet
Date:    04/21/2000  6:13 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am surprised at some of the Securities Industry Association positions you have
received:
     
"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."
     
Come, come now. I try to, and at our investment club, we're all learning how to 
do it and how to do it better. And we're not alone. We don't "pore" because it's
not our full-time job, but then I only have a handful of stocks to follow 
because I've been told (not by my broker, by the way) to not have more than I 
can do a decent job of following.
     
I know people who have brokers who expect them to invest as they are told to do.
They've been losing money over the last five+ years. The above statement only 
affirms my belief that brokers/analysts pretty universally believe that we are 
just a bunch of airheads who need to pay them to take care of us and frankly, my
impression is they don't do a very good job of it.
     
On the other hand, even though I do my own research I won't give up my broker, 
because I need someone to reel me back in when I get carried away or make 
half-cocked decisions.
     
"But it does need to be said that analysts cannot do their work nearly as well 
as they do now if they are forced to do their work, at least when it comes to 
interaction with issuers, collectively -- in a pack."
     
So is/are the analyst(s) at my broker (MSDW) going to be excluded? Probably not.
(They're probably busy arguing the opposite of what I'm saying!) But I don't 
want to have to worry about that ever happening. And what about the ones 
selected? Are they the ones most favorably inclined to the company? the most 
bullish? the most bearish? I think if we look at the state of the press today, 
most everyone except the press will agree it is appalling and getting worse. 
They may or may not know the truth, but they write it, edit it, time it, and lay
it out based only on what will sell papers. Analysts are no different, and 
insofar as they depend on information from companies, they should be.
     
"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."
     
This is exactly my objection. An analyst who is "firstest with the mostest" 
should provide the best analysis, not the best scoop. If other analysts are not 
provided the same information, then why should the one who is "first" be 
believed? How will their information be verified? Yes, yes, I read the part 
about tone of voice, but even something like that should be verifiable -- on 
tape or some other way.
     
Worse, does this mean I need a brokerage relationship with dozens of firms? One 
with XY&Z who have the "in" with MSFT and CSCO; one with AB&C who have the "in" 
with EBAY and AOL; one with RS&T who have the in with GE and LU; and so on? Or 
do I switch brokers regularly to the newest "firstest with the mostest?"
     
Judy Petersen - mailto:judy@talstar.com

 Author:  Jonathan Pierce  at Internet
Date:    04/21/2000  2:29 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: "'japierce1@uswest.net'"  at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Break the Hegemony of Wall Street.
     
It is not a fair business practice for a public company to release discreet 
information to analysts without disclosing it to the public.
     
The practice of organizations withholding information from the population is 
not a new practice, nor will it stop in the near future. For several hundred 
years, the Holy Roman Church held control over all written information in 
the western world. The side effect was an educational elitism. Only the rich 
could be educated, and even then, only with the information that had 
received the papal stamp. The invention of the printing press broke this 
educational hegemony. Slowly the population educated themselves, and the 
free exchange of ideas blossomed through the western world. This story runs 
parallel to the hegemonial hold that Wall Street has held over investing 
information.
     
The Internet has become the modern day equivalent of the printing press. The 
number of individual investors has risen dramatically. Large amounts of 
information are available to all. What was once the sole institution of 
"Wall Street" and "Analysts" is now available to a much broader market. 
Public companies have had to court Analysts in order to gain value in their 
stock, but the market is no longer restricted to the select few. A source of 
capital is available to companies that was not availble before, and those 
who hold this captial and are actively investing have a right to all the 
information.
     
Regulation FD: File No. S7-31-99 is a good regulation providing equal 
information to all investors.

 Author:  Boris Rimensberger  at Internet
Date:    04/21/2000  3:08 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I am very much in favor of this proposed rule to level 
the playing field with regard to when and whom 
important information is released by companies.
It is blatantly unfair that Wall Street Analysts get a 
significant time advantage over individual investors 
as to when information is made available.These 
analysts gain a great financial and reputational 
awards from presently obtaining this information 
first.
     
The slant by the SIA filing that individual investors 
must be protected and guided by analysts, that they 
collectively cannot extract relevant facts from 
company releases, that the markets would be less 
efficient, etc., etc. is all hogwash.
     
Individual investors have the right and the 
capabilities to process released company information 
on their own, at the same time the analysts get the 
information.
     
I am personally connected to the Internet but am 
always astounded by the huge time delay between price 
action on a particular stock and the point in time I 
finally am able to find out what has caused this 
action. 
Of course, the analysts have taken the info and acted 
upon it in a timely fashion for personal financial 
gains for their own accounts and/or preferred 
customers.
     
Boris Rimensberger
1521 Maurine Place
Fullerton, CA 92831
     

 Author:   at Internet
Date:    04/21/2000  5:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Proposed Regulation FD: File No. S7-31-99
     
I oppose this rule change.  I feel that individuals should have access to 
company information at the same time that the wall street analysts do.
     
John Shaw

 Author:  Rajwinder Singh  at Internet
Date:    04/21/2000  6:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
TO: rajwi@bu.edu at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Chairman Levitt & SEC Board,
     
I am writing to express my strong support for the Proposed 
Regulation FD, File No. S7-31-99. I very much appreciate the 
market fairness that the Commission is striving to promote 
and thank you for the same.
     
I have read the response of the SIA's ad hoc working group 
on the subject. Stripped of its jargon and sophisticated 
language, and translated in plain English, I read the 
response to be saying, among other things, that the 
individual investors (or investment clubs/collectives etc) 
are too stupid to understand the information they might get 
from companies. The SIA seems to think that the public needs 
to be guided by some financial high priests, aka "analysts" 
to wade through the waters of the market.
     
The SIA's stand is contrary to the direction of progress of 
information access and processing by all manners of public 
institutions and individual members. In other words, the SIA 
is trying to guard its analysts' meal ticket in face of their 
increasing obsolescence. This move by the SIA flies in the 
face of direction of history of the world's economic 
progress. I have no doubt you understand well the kind of 
incestuous relationship the information-privileged analysts 
will try to form with companies in the face of increased 
obsolescence of their positions and faster, cheaper and 
efficient access to information by the public.
     
Rapid change in tune with technological and economic reality 
is the greatest strength of America's economic system and 
any artificial barriers, particularly in the most important 
economic resource of the 21st century -- namely information 
-- will greatly weaken this strength. As the communication 
and information channels have become faster and accessible 
to the public, the SIA information filters ("analysts") have 
turned into ever-incongrous, anomalous, barriers.
     
Please do not let the lawyers of the SIA obfuscate this very 
important issue and implement the proposed regulation as 
soon as possible.
     
Thank you,
     
Rajwinder Singh    rajwi@bu.edu
23 Creighton Street
Cambridge, Massachusetts
     
     
     

 Author:   at Internet
Date:    04/21/2000  6:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" 
------------------------------- Message Contents 
This is in direct response to the submission of The Ad Hoc Working Group on 
Proposed Regulation FD and the Legal and Compliance Division of the 
Securities Industry Association ("SIA"). 
!. The statement "it hardly needs saying that analysts perform a necessary 
and valuable function in the U.S. capital markets," is questionable. Analysts 
regularly recommend stocks as buys and such stocks subsequently drop in price 
even when the averages advance; and regularly recommend stocks as neutral or 
market perform ( there do not seem to be any sell recommendations anymore) 
and such stocks subsequently rise even when averages drop; and regularly 
place outrageous targets on momentum stocks getting their prices to double or 
triple in a matter of days before dropping back to earth.  It is hard to 
believe that such recommendations are not related to trades made by their own 
houses and/or favored clients.
2.  The suggestion that analysts need better information than the 
participants in the market is outrageous.  With what amounts to inside 
information analysts and their favored clients can start buying and selling 
before the rest of the participants in the market.  They know if a sudden 
move up or down has legs based on their inside information while ordinary 
participants can only guess.
3.  The statement is blatantly false that the "alternative model of millions 
of individual investors and potential investors poring over prospectuses and 
periodic reports is highly theoretical and out of sync with the real world." 
I for one already read prospectuses and periodic reports, and I know that 
most serious investors do, also.  After poring over such documents, I should 
also be privy on a timely basis to inside information which may supplement or 
modify them. 
4.  With respect to the statement that analysts make the markets less 
volatile,  I can not understand how one can make such a representation.  From 
my observations, analysts' recommendations move individual stocks and groups 
of stocks.  Without such recommendations there would be much less volatility. 
5.  The statement that analysts spend much of their time ferreting out 
negative information about companies may be true, but they do not immediately 
share such information with the public.  Instead, they appear to give this 
information first only to their own houses and selected clients which unload 
stock on the public before the stock's price drops.  Thus, the public's 
losses are magnified by the analysts' sole possession of such information 
while their own houses' and selected clients' losses are minimized.
Proposed Regulation FD: File No. S7-31-99 should be adopted without delay. 
Respectfully submitted,
Joel Spitzer
18 Marconi Drive
Latham, NY 12110
     

 Author:   at Internet
Date:    04/21/2000  6:06 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents 
It has come to my attention that the proposed regulation would be helpful to 
me as an independent investor by requiring, among other things, that 
companies no longer engage in the practice of discreetly disclosing important 
information to Wall Street analysts without also giving the information to 
the public at large. I highly favor passage of this regulation. For too long 
the indepent investor has been treated as a moron that are injurious to 
themselves. Let me assure you that is in not the case.
I digest annual reports, perform extensive research and determine my own 
investments as well as my family's and have been quite successful. So the 
Wall Street brains aren't the only persons that are capable of doing this, 
and I know there are a lot of other investors that are doing the same as I am. 
Thank You,  Tom Stuckey  at: tstuc91866@aol.com

 Author:  Reginald Vincent  at Internet
Date:    04/21/2000  4:26 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Sir/Madam,
     
I would like to add my comments reagrding the above-mentioned changes and the 
findings of the Ad Hoc Working Group. With all due respect, I feel that this 
is the most ridiculous findings I have ever read. I can see that this 
committee is comprised of individuals with self-interests who has been and 
stand to gain extremely by NOT disclosing information to the people. 
     
I am an individual investors who have lost my trust in these so called "Expert 
Analysts of Wall Street" since the day I realised that they are not interested 
to make me money, but themselves. Since then,  I am glad to say that my 
portfolia has done much better than the market, has beat ALL the mutual funds 
and have made a mockery of most analysts. A prime example is the analyst 
predicting Qualcomm to reach $1000.00 in stock price. We have all seen the 
price of that stock falling ever since.
     
I know that the SEC is working for the interests of the people and I hope you 
will take your time to ponder all the importatnt points and make these changes 
so the information can be passed on to individual investors like me.
     
Thank you,

 
     
Author:  "Craig Weatherford"  at Internet
Date:    04/21/2000  6:19 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
I think I am as entilted to information as anyone else.  It is not rational to 
state that only the Big Boys should get the information because me the little 
guy cant figure out how to use vital information.  We are educated.  To deny 
this is to say that only the chosen should benefit.  As a Canadian I am laughing
when I read "equal rights for all".  Humm, I guess your forfathers were not as 
smart as you guys.
     
Craig.
     

 Author:  "Jay Zeilenga"  at Internet
Date:    04/21/2000  3:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sirs:
     
I am strongly in favor of this proposed regulation. I don't need to have 
this information filtered by Wall Street analysts, many of whom are, in my 
opinion,  lazy and just follow the herd.
     
Sincerely,
Jay Zeilenga
     

 Author:  "Ed Zoolalian"  at Internet
Date:    04/21/2000  3:00 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
PLEASE PASS THIS REGULATION!   The individual investor IS smart enough to 
understand whatever is disclosed by companies.  And if he is not - there is not 
harm done so why fight this regulation so hard?  It is because professionals 
want to keep their hold on individual investors.
     
     
     

http://www.sec.gov/rules/0421b06.htm


Modified:04/28/2000