Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Richard" at Internet
Date: 04/16/2000 6:57 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. s7-37-99
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I believe selective discloure is ILLEGAL.
Richard L. Bell
Author: "Edward Couble" at Internet
Date: 04/21/2000 11:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please pass this rule. I need the straight info to analyze my stockbrokers
analysis and comments. I am skeptical that my brokers
underlying interest is not in my best interest.
Edward Couble
143 Tosca Dr
Brockton, MA 02301
Author: "Ronald & Janna Drobny" at Internet
Date: 04/21/2000 8:55 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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Dear Sirs:
I want to let you know that I Strongly support the position that individual
investors should have access to the same information as wall street "analysts"
and that information should be available at the same time. The analysts should
not be privy to information that is being withheld from the general public.
The view of the SIA that analysts should have access to the information prior to
the public is unfair and without any reasonable justification.
I have worked in the financial services industry for a number of years and have
read more analysts reports than I can count. I am sure you will agree that many
of these are nothing more than am "analyst" expressing the current views of
management of the company being "analyzed".
It is important and fair in the current information age for all investors to
access to the same information at the same time.
Sincerely,
Ron Drobny
Author: "Omar Gonsenheim" at Internet
Date: 04/21/2000 10:18 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Gentlemen,
In reference to the above proposed regulation, it is my opinion as a small
independent investor that ALL relevant company information should be
available to ALL players on an equal basis, as contrary to what the current
beneficiaries of the existing system would like us to believe, a better
informed investor is a better investor.
Analysts and full service brokers are losing ground because more and more
individual investors have chosen to make their own decisions which has made
the markets less subject to large institutional trades that exacerbate
volatility should result in more transparent markets that will ultimately
benefit the overall public.
Sincerely,
Omar A Gonsenheim
Author: "P & D Gruntorad" at Internet
Date: 04/21/2000 8:46 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Gentlemen:
The public urgently needs for companies to no longer engage in the practice of
discreetly disclosing important information to Wall Street analysts without also
giving that information to the public at large.
In this "age of information", those who are willing and able to manage a portion
or all of their own stock portfolios should be allowed to do so with the full
disclosure allowed Wall Street analysts. Only with full disclosure will we all
become "full partners" in the management of our finances, much as we have become
with our physicians in our healthcare, with all of the medical information we
now find available.
I understand that the Securities Industry Association stated "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." I hardly
think that this is true for us, or for many of our close personal friends, or
indeed, many in the community. We individually and collectively do this now,
both alone and informal group discussions, and in formal groups such as
investment clubs both locally, state-wide and nationally. We fail to understand
how this would force analysts to do their interaction "....in a pack."
With regard to "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." Yes, it would level the playing field, but it would level it
across the board by granting access to information to all. This would go a long
way toward eliminating deception from the analyst/client relationship. It
would, in the end, provide a check and balance system that the client could use
to evaluate the service provided by his/her analyst and buoy confidence in
analysts who stand the test, even before one committed funds for investment.
We fail to see how analysts make the market less volatile. Anyone who is
employed and paid only by the amount that is traded must, of necessity,
encourage others to buy or sell. One only need watch CNN to hear analysts
simultaneously saying buy/sell the same equity. This hardly makes a less
volatile market!
We request that you rise to the challenge to move us on to complete disclosure
for all. Only then will you be truly serving the public, not a special interest
group.
Sincerely,
Dennis L. and Patricia D. Gruntorad
Author: at Internet
Date: 04/21/2000 11:41 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: I support Proposed Regulation FD: File No. S7-31-99
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Open all information to all investors.
William J. Harrison Jr.
Author: "Stephen Herzog" at Internet
Date: 04/21/2000 10:55 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation S7-31-99
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I am writing to express my support for the proposed
regulation "Selective Disclosure and Insider Trading",
File No. S7-31-99, Regulation FD.
I believe that it is only fair that companies who release information should do
so to the public, and not a select few.
Stephen Herzog
Beaverton, OR
Author: "William G. Ingersoll" at Internet
Date: 04/21/2000 10:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor I believe that the only acceptable standard for a
free market is for all information to be available to all participants
equally. The only arguments I have seen that are contrary to this view are
specious and self-serving. I strongly recommend the enactment of Proposed
Regulation FD.
William G. Ingersoll
Author: "mjcalab" at Internet
Date: 04/21/2000 11:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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RE: Proposed Regulation FD: File No. S7-31-99
Dear Sir:
I totally disagree with the position of the SIA regarding this matter. It is
clear, that they do not have the interest of the public in mind only their own
pocket books. We have a right to receive the same information they receive and
at the same time. We expect our representatives to support us in that right.
When they present their arguments to you do they really think you are dumb
enough to believe their arguments? That you can't see through their
self-severing arguments? You should let them know you are not fools by
supporting the publics rights to timely distribution of source information
without modification by anyone.
Sincerely yours,
Michel N. Jacoby
Author: Michael Kerekes at Internet
Date: 04/21/2000 10:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I have been astonished to learn that publicly-traded companies routinely
make important information available to only a small segment of the
public. I, as an independent investor, consider myself well-qualified to
evaluate information provided by companies and believe that I am placed
at a grave disadvantage in the markets if I do not have access to all
information that is disseminated by a corporation.
Individual investors should not be forced to invest through or purchase
the services of an analyst simply in order to have access to such
information. As I understand it, the proposed regulation will prohibit
corporations from favoring particular analysts or other persons by
providing them with information unavailable to the general public. I
believe that, especially during a period when progressively more
investors wish to invest independently, promulgating such a rule is
essential to economic fairness and to the public's confidence in the
operation of our securities markets.
Thank you for your attention.
Michael S. Kerekes
1220 Sunset Avenue
Santa Monica, CA 90405
Author: "Michelle Knijnenburg" at Internet
Date: 04/21/2000 10:07 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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RE: Proposed Regulation FD: File No. S7-31-99
Please make this rule a law. The rule (Proposed Regulation FD) would
require, among other things, that companies no longer engage in the practice
of discreetly disclosing important information to Wall Street analysts
without also giving that information to the public at large. It's a pretty
commonsense rule in our opinion, one that many investors might logically
assume must already be the law of the land, but unfortunately isn't. We
understnad that Wall Street is arguing that maintaining the current system
is not just in its own interests, but in yours as well. We disagree. The
proposed rule was and is an outstanding one for individual investors.
Please implement Proposed Regulation FD. It is in the best interest of the
individual investor, who IS mature enough and entirely capable of handling
said information without a knee-jerk reactions to specific information. In
fact, this helps to level the playing field.
Sincerely,
Individual Investor Cor Knijnenburg
Individual Investor Michelle Knijnenburg
Both of Carrollton, Texas .... usanl@home.com
Author: "Hugh Lee" at Internet
Date: 04/21/2000 10:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD: file no. S7-31-99
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it is totally unfair that companies give Wall Street anlaysts company
information before it is disclosed to the public. something must be done to
correct this. make sure that the public is given the information at the same
time that these analysts are given the info.
Hugh K. Lee
Author: "Gottfried" at Internet
Date: 04/21/2000 10:12 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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As an individual investor I strongly support the proposed rule,
as it will make company information available simultaneously to all.
Regards Gottfried Mauersberger
1137 Revere Drive
Sunnyvale, CA 94087
Author: "Joel Nevison" at Internet
Date: 04/21/2000 10:30 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hello, I just read Bill Barker's column 'Wall Street opposes level playing
field' at the Motley Fool.
I support the proposed fair disclosure regulation. As an individual
investor I do all my own research for my stock purchases. Additionally, I
learn from hundreds of other investors who also research on their own.
Sell-side professional analysts, in particular, have a bias toward
generating trades that leaves me unwilling to accept their research at face
value. For them to have privileged access to company information that I as
an individual investor can not get just makes the situation worse.
Thank you for you consideration
Joel Nevison
130 Townsend St
Grass Valley, CA 95945
Author: Kyle Nishioka at Internet
Date: 04/21/2000 9:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an investor and an American citizen, I find it disturbing that
information regarding publicly held companies are disseminated to a select
few individuals in advance of the public at large. This regulation is
an absolute necessity to protect the integrity of the U.S. stock market.
Kyle Nishioka
Author: srahe at Internet
Date: 04/21/2000 10:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed egulation FD: File No. S7-31-99
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Only if their firms were somehow prohibited from taking any position
would it be fair to continue to give them special confidential
information. And that obviously isn't going to happen.
Let the analysts analyze in the light of full disclosure and end the
duplicity of their dealings in the shadows of their being "privileged
filters".
steve rahe
Author: Larry Ronhaar at Internet
Date: 04/21/2000 10:55 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Having read the SIA's position on the proposed regulation, I would like
to offer my observations.
1) Analysts may provide some valuable information to investores, but too
often they are lemmings who would follow each other over a cliff. There
is far too little original thought, and they far too often take
positions that benefit their employers. As such, analysts are not
deserving of preferential access to information.
2) I have an MBA and I do read prospectuses and periodic reports. I
don't need a Readers' Digest version from a bunch of analysts.
3) I believe strongly that the analysts and their "pronouncements"
increase market volatility rather that decrease it, as the SIA contends.
4) Very few analysts spend enough of their time ferreting out negative
information about the companies that they follow. First, their frequent
publication of negative information would adversely impact the
relationships that their employers may have with the companies. Second,
if they did it too often, their own access to the movers and shakers in
the companies would eventually be limited. Publication of negative
information by an analyst can too easily be self-defeating. If they lose
access to their sources, they lose their jobs. Why would they do that?
The bottom line question is "Is the information that analysts dispense is
unbiased? Is it influenced by whether their employer was and advisor on
the last deal, or if they hope to be on the next one. Does their
employer have a shot at the next IPO or secondary offering? Is their
employer a market maker for the company's stock? How much of the stock
does the analyst own? If any of these factors influence the published
opinions of the analysts, they and the SIA cannot be trusted with
preferential access to information about publicly traded companies.
James L Ronhaar
2630 Biscay Way
Walnut Creek, CA 94598
Author: "Bill Simpson" at Internet
Date: 04/21/2000 11:08 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Please pass this regulation. I for one can honestly tell you I read prospectus'
weekly and am fully capable of deriving my own conclusions as to the merits of
owning or selling a particular company's stocks......if given equal information!
Thank you.
Bill Simpson
CEO
BCS Ventures
Author: Aubrey Keith Sparkman at Internet
Date: 04/21/2000 10:58 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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1) Do you really believe that analysts spend much of their time
ferreting out negative information
about companies? I don't.
2) Do you really believe that analysts make the markets less volatile?
I don't. Look what Abby did.
3) Do you really believe that I as an individual investor am out of sync
with the real world and need an analyst to read prospectuses for me? If
you do, then why are you trying to make them easier to read?
4) I believe that analysts perform a necessary and valuable function for
their clients. Let them work for those who need them. But In a "free
market" how can you justify letting one group get better information
sooner than the other participants in the market? Who gets to pick
which group gets the information first? Let me decide. I want it
first. That is a very important competitive advantage which should not
be restricted to a priveledged class.
Thanks for your time,
Aubrey Sparkman
Individual Investor.
Author: "Jon Wilson" at Internet
Date: 04/21/2000 8:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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In the end it is always our money at risk and we should have the right to know,
not just a group of self serving elitist! Do the job of the people, not the
select few!
John Wilson
Lopez island , WA 98261
Author: Yanchen Ng at Internet
Date: 04/23/2000 8:30 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD: File # S7-31-99
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Dear Sir
It's hard for me to comprehenda double standard that you have
maintained; one for the public and one for the selected few investment
house. I am a full time stock investor, doing my reserch and investing
my money the best that I know how. The past four years has beed
rewarding that I enjoying a 50 - 100% return yearly. I subscript to no
news letter or other suggestion financial reports from any investng
house.
Change happened overtime, and for those that take no notice of it will
either steam roll over or fall over cliff without a second chance.
Please straighten your rule by changing one for all; one for the
investment house and one the same for the private investor. Thank you.
Warm regards
Teck Wong
Author: Don Youkey at Internet
Date: 04/21/2000 9:40 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Thank you for extending the comment period on this important decision,
Proposed Regulation. Now that Wall Street is making the news in
attempting to preserve it's monopoly on information, I hope you hear
from quite a few individual investors that want the same information
directly from publically owned companies. It's ludicrous to think that
professional analysts are the only ones that can properly interpret such
information. Sure, these analysts perform an important function of
interpreting this information for investors, but most investors are
perfectly capable of doing it themselves, given the chance. If this were
truly a free, open, capitalistic market, information would be released
to the public at large. Don't let the special interest groups of Wall
Street pad their own wallets with what amounts to "insider information",
at the expense of independant individual investors - many of which are
also owners of the very companies withholding timely information from
them. In reality, few analysts will loose their jobs - it takes some
effort to ferret out useful information. But it certainly is not above
the average persons comprehension to do it.
Thanks for the opportunity to comment.
Don Youkey
8490 Valley Blvd.
Juneau, AK 99801
dyoukey@gci.net
Author: "Ken Zagzebski" at Internet
Date: 04/21/2000 10:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. 57-31-99
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Proposed Regulation FD: File No. 57-31-99
The full service brokers are so full of themselves. Even if they could
ferret out better information, I would not trust their recommendations,
which are more often than not colored by conflict of interest where they
hold the stock themselves, are a market maker of same, etc.
Adopt the propsed regualtion as soon as possible.
Ken Zagzezbski
An Individual Investor
Author: Jonathan Ziebarth at Internet
Date: 04/21/2000 10:10 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hello,
I am an individual investor in favor of Regulation FD.
Thank you,
Jonathan Ziebarth
Graduate Student
Stanford University
http://www.sec.gov/rules/0421b09.htm
