Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Arthur Anderson" at Internet
Date: 04/22/2000 12:01 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Honorable SEC members:
Please support the legislation to require full public disclosure of all
information concerning public companies as well as any other information
concerning our lives. It is essential that each and every person has full
access to as much information as any other person, if this country is to avoid
the terrible mistakes of the past where "Philospher Kings", dictators, and only
certain privileged people controlled a country's destiny by controlling
information.
We all know what happens when the news is controlled. Millions of our "average
citizens" and veterans have fought and died to keep that from happening since
the very beginning of our country and I know you and all of us would do it again
if necessary.
This a matter that has far greater consequences than it's current focus. It is
a principle which can not be compromised. As a nation we can not take the first
step down that road of controlled information. The defeat of this bill will be
terribly destructive to all our freedoms.
You have sworn to protect and perserve our freedoms. Your help in passing this
bill will help do just that.
Respectfully.
Arthur E. Anderson
612 Lake Ave
Hancock, Mich.
(temp: Gulfport, FL.
Author: Bridget Boyle at Internet
Date: 04/22/2000 6:22 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 able to make my own decisions regarding which stocks to buy. Open and
equal access to all parties, "professional" or not, should be allowed.
Bridget Boyle
Corona, CA
Author: at Internet
Date: 04/22/2000 8:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs:
It seems to me there are two choices:
1. Full disclosure to everyone at the same time.
2. Private disclosure to analysts which is treated as insider information
until it has been published and enough time has elapsed for it to be
distributed to everyone. The analysts nor their employers should be able to
benefit from private disclosure.
Rules should be adjusted to acknowledge the changes brought about by internet
access to stock trading for individual investors.
Eric R. Carlson
54 Princeton Road
Fair Haven, NJ 07704
Author: at Internet
Date: 04/21/2000 7:18 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Let's make the game more honest and fair and let everyone have access to
the information that companies now share with analysts. The "not
intelligent enough to handle this info" is ridiclulous. If we arel
intelligent enough to "buy and sell", we are deserving of the facts.
Please do whatever it takes to level the playing field.
James A. Cox
120 Pembroke Street
Boston, MA 02118
Author: at Internet
Date: 04/22/2000 12:05 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Analysts should not be the only ones receiving company information. I should
have that available to me at the same time the analysts do. Not to do so is
to continue the insider deals going on & to hurt the individual investor. Tom
Cummins
5923 Woodridge Rock
San Antonio, Texas 78249
Author: at Internet
Date: 04/22/2000 5:21 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir;
I would like to urge you to ensure that the proposed regulation for fair
disclosure be passed as a requirement for all companies give equal disclosure
to the public investor. The public has been not been provided fair access to
pertinent information in a timely manner.
I would also urge you to look into the matter of market makers "runnings
stops". This, in my opinion, is unarmed robbery and should be a criminal
offense with a stiff jail term upon conviction. Innumerable small investors
have had their stocks stolen from them at below market prices only to see the
stock's price bounce right back up 2 minutes later. It has happened to me a
number of times and makes me believe that Wall Street is run by a bunch of
crooks.
Sorry if my anger shows up a little but with a mugger I at least have the
option of defending myself.
Sincerely,
Joseph P. Dugan
727 N. Sterling Blvd.
Sterling, VA 20164-3830
(703) 444-2892
e-mail - JOEDUGAN@aol.com
Author: at Internet
Date: 04/22/2000 7:55 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I wish to comment on the proposed rule for fair disclosure of information by
publicly traded companies to the public. As a retiree with virtually all of my
retirement assets in a self directed IRA, it is extremely important for me to
carefully and cautiously consider the ramifications of each individual
decision to purchase and sell individual offerings. I understand the
analyst/brokerage community is against the proposed rule and have listed four
reasons for their position. My comments regarding their four points are as
follows:
1. Why would analysts need better information than the investing public in
order for them to conduct their business? It seems to me that as a member of
the investing public I should demand the right to all relevant information
without its first being filtered by any special interest group.
2. While professional analysts certainly are better trained and equipped than
the general investing public to analyze prospectuses and periodic reports,
that should not presuppose that the investing public as the people who will
endure the capital risks of their investments should not be privy to the same
information in the same time frame as the analysts.
3. The assertion that analysts--at least partially by the virtue of their
haing exclusive rights to certain information--create a less volatile market
for securities is a rash assumption. Even if it were true, that alone should
not be reason for their having a priveleged status to receive exclusive
information.
4. Negative information about companies and potential investments in those
companies would still have currency if analysts were not the exclusive
recipients of information. After all, isn't that what our news media thrives
upon? Analysts, too, would still have an interest to ferret out negative as
well as positive information in order to gain an edge on their competitors
(both within the analysts/brokerage community and without) to add to their
credibility and to gain clients for their employers.
Kenneth M. Ebner
1336 San Mateo Drive
Punta Gorda, FL 33950
Author: Dr E at Internet
Date: 04/22/2000 2:14 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 write you to support the proposed regulation, quoted above.
Earlier the priests, later my peer group, the physicians had to see that
their "secret society", maintained "for the protection and for the good of
all mankind" had to be opened up to let the layman in and see them
participate in deisions of vital importance to her/him, both in the
spritual and in the physical realm.
The sun still rises and the dire consequences predicted regarding the great
perils caused by the weigth of knowledge now to be borne by mere
laypersons, have not been widely observed, in the church nor in the
sickbed. At least I have not heard of it.
We now see a repeat of the same phenomenon: according to the entrenched
financial insiders laypersons cannot bear the burden of knowledge of
companies and their stocks, so meetings between company leaders and Wall
Street analysts and other gurus should remain sedcret and behind closed doors.
The proposed regulation will create a healthy open atmosphere and permit
everyone to make informed decisions. If laypersons feel they need help to
interpret their findings they will know where to go. Give us credit for
knowing what to do.
I repeat my strong support of the above-quoted regulation.
Yours sincerely,
Dirk Enthoven, MD, FACG
315 Mine Brook Road
BERNARDSVILLE, NJ-07924.
Author: "Steve Fisher" at Internet
Date: 04/22/2000 12:58 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Disclosure of Information to the Public
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I am in favor of an SEC rule making corporate information available to the
public and not just to a few analysts.
SAF
Author: at Internet
Date: 04/22/2000 12:34 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD
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Dear Sirs:
In reading the comments of the SIA concerning Regulation FD, I am amazed
at the patronizing tone of their comments, as well as the totally self serving
nature of the comments. I feel that the open, public disclosure of corporate
financial information can only serve to "level" the playing for all. How
could this be contrary to the public interest? Conversely, pre-disclosure only
to the chosen few only serves the interest of those chosen few, making them
appear to be more useful, more insightful, more powerful, more influential,
and better able to interpret for those of us in the "lay" public. In contrast
to the views of the SIA, I do not feel it is evident that analysts perform a
necessary and vital function in the market. Just like doctors, teachers,
lawyers, salesmen and others, some perform a worthwhile function, and some
don't. Certainly, making information readily available and easy to obtain is
much more "in sync" with the real world, than is the practice of selective
release only to the elite few who are somehow thought to be necessary to pass
it on to the ignorant masses. This is somewhat akin to the Medieval practice
of keeping the Bible in Latin, so that only those scribes and priests with the
right education could read and interpret scripture for the public masses, who
were obviously incapable of applying God's word to their own lives and
situations.
I can agree that, with public disclosure, the analysts will not be able
to do their work nearly as well, and this would probably result in lesser
salaries from their brokerage houses, less personal fame, less ability to
cause stock price swings based on their comments, lesser TV ratings, and
perhaps even fewer subscriptions to their private newsletters. How will the
market remain efficient in the face of these momentous changes? We can only
hope and pray that somehow we could all survive in this brave new investment
environment!
Please consider the fair disclosure of corporate information to the
public. It is not only the common sense thing to do, it is the right thing to
do.
Sincerely,
Gene N. Gordon,
M.D.
Author: at Internet
Date: 04/22/2000 9:07 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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21 April 2000
To: The Ladies and Gentlemen of the SEC,
From: Mr. William Guilford II
3987 Hartlake St.
Woodbridge VA 22192
1. I think it is propostorous to think that I should not have the same
access to securities information as brokers employed by major brokerage
firms. Simply because they have more purchasing power should not mean that
they have any advantage over any other individual investor. All investors
should have the same level of access to ALL securities information. We are
smart people, and can make decisions just as well as any broker can. The
current system of giving advantages to brokers and other big-time investors
needs to change. Feel free to Email any concerns to Guilwe5678@aol.com.
Thank you for your time.
Mr. Bill Guilford
Author: "kathyh" at Internet
Date: 04/22/2000 8:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor, I am writing to ask that you put an end to the
patently unfair practice of allowing publicly traded companies to disclose
information to small groups of analysts, rather than equal disclosure to the
public at large.
Passage of this regulation will allow me as an individual investor a level
playing field with the big brokerages on Wall Street. Until I heard about this
proposed regulation, I must admit I had assumed this was already the case under
the law, equal disclosure to everyone. I now know that is not the case, and I
urge you to pass this regulation as soon as possible.
Sincerely,
Kathy Hatfield
Author: Allen Hough at Internet
Date: 04/22/2000 6:21 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Sirs -
This is in regard to the subject proposed regulation.
Companies should no longer engage in the practice of discreetly disclosing
important information to Wall Street analysts without also giving that
information to the
public at large.
To quote the Motley Fool, "It's a pretty commonsense [proposed] rule in my
opinion, one that many investors
might logically assume must already be the law of the land, but
unfortunately isn't."
I try to do my own homework and form my own opinions. I am a semi-retired
investor. I learned about investing from my parents, one of whom, at 97,
is still an active investor, following the market information and carefully
(and with painfully weak eyes) reading the annual reports and other
information coming her way. She has an investment advisor, but she also
reads the stuff herself and forms her own opinions. My sisters and I do
likewise, following the training and example of our parents as well as our
own thinking.
The SIA's filing to you in opposition to this regulation is
self-serving. I am strongly in favor of your proposed rule, and encourage
you to proceed with it.
Investors need to know when the information they are reading /hearing is
"from the horse's mouth" and not the result of unidentified predigestion.
Allen Hough
allen@axnet.net
619-938-0242
Author: at Internet
Date: 04/22/2000 2:57 AM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION NO. S7-31-99
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IAM STRONGLY IN FAVOR OF HAVING ALL INFORMATION AVAILABLE TO THE
PUBLIC AT THE SAME TIME IT IS MADE AVAILABLE TO ANALYSTS.
SINCERELY
PATRICK A. KELLIHER LIVONIA
DESIGN INC. 1-734-464-2471 OR FAX
1-734-953 8648 PAK1913@AOL.COM
Author: Stefan King at Internet
Date: 04/22/2000 6:17 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
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I feel that the present system of non-disclosure of
financial information is wrong, and constitutes
something very nearly akin to a legal "racket".
I work on Wall Street as an IT consultant, but there
are certain aspects of the present securities trading
system which I will not defend as I believe they are
indefensible. It is not hard to fathom the reasons
for the oppostition to liberalization of information
release. Possession of secret data is a very valuable
thing in this environment. This kind of thing is
also undemocratic and immoral and should have
no place in a nation of free individuals.
Stefan King
independent consultant
Author: at Internet
Date: 04/22/2000 8:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed rule regarding financial information available only
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I strongly support the adoption of the proposed rule which would limit
companies' ability to release financial information to financial analysts and
not to the public. I believe that the strength of our marketplace resides in
its transparency, and the willingness of the public to trust market
valuations. A system which allows a hierarchy of financial information in
the publicly traded markets can only erode public trust in the efficiency of
the market, and can, therefore, only lead to a less efficient market place.
Sincerely,
John Lafleur
Author: Marc Liebeskind at Internet
Date: 04/22/2000 3:06 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 am writing to voice my support for the above-referenced regulation. I am an
individual investor, and believe strongly that in order for me to make the most
intelligent investment choices, that companies be prohibited from selective
disclosure, and instead be compelled to disclose their financial information to
everyone at the same time. This would indeed provide a level playing field,
enable all investors to participate equally in their investment decisions, and
prohibit unscrupulous analysts from swaying the market with their own investment
biases.
I would also suggest that instead of quarterly reports being the sole reporting
requirement, that a monthly disclosure requirement be instituted. This would
keep all investors up to date with corporate information, help to protect
investors from loss, and reduce market volatility as it would disclose more
relevant trends in the marketplace and with a particular company. It is
unlikely that this would cause any real burden on the companies, since these
numbers are constantly being generated and easily computerized.
Thank you for your attention to these comments.
Very truly yours,
Marc Liebeskind
Author: Michael Gusovsky at Internet
Date: 04/22/2000 3:26 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To: Jonathan G. Katz, Secretary
Dear Mr. Katz,
It is with great hope that we have read about the proposed
Regulation FD. In an open, free, and fair marketplace, equal access
to information regarding investments needs to be available to all
investors and all interested parties.
For too long have brokerages usurped the power and knowledge
that should be available to all, claiming that analysts, by virtue of
their profession, are entitled to exclusive access to vital company
information, that they alone are able to come to valid conclusions
regarding the company in question. Of course, when such exclusive
and valuable information is granted to these analysts, there tends to
arise a strong natural bias by these analysts in favor of the company
granting them this exclusive information, lest they should fall out of
favor with the company and it should cease to provide them with the
favor of the exclusive information. That is to say, this arrangement
provides for a strong financial incentive for companies to provide
exclusive information to analysts that will comment on them in a
positive light, as well as a strong financial incentive for the select
chosen analysts to comment on these companies in a positive light,
so that they may continue to receive this exclusive information. The
end result, of course, is that these companies and analysts that
participate in such arrangements benefit at the expense of investors
by means of duplicity.
The Securities Industry Association, lobbying jealously on behalf
of brokerages to retain their exclusive privelege, makes the
misguided claim that this sort of quid pro quo situation is a rare
aberration, rather than the norm, as if to state that the vast majority
of analysts are completely uninfluenced by the payments given to
them by companies in the form of exclusive financial information,
and will remain perfectly objective. While it is true that some
individual analysts may be of superior moral character, it begs the
question, "Why allow the fox into the chicken coop in the first place?"
We believe that Regulation FD is a step in the right direction,
providing for a level playing field and the end of unfair privelege at
investors' expense. We would therefore like to voice our strong
support of this excellent proposal.
Very Truly Yours,
Britt Lindberg
Michael Gusovsky
37383 Sequoia Road
Fremont, CA 94536
Author: sheila marsh at Internet
Date: 04/22/2000 1:07 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 very concerned about this issue. It is very apparent to me
ferreting out negative information about companies is not always in the
best interest of an analyst as the analyst "needs" his "sources" for his
bread and butter. But it is in MY best interest to ferret out both
positive and negative information to decide how best to invest my
family's money. I am astonished to learn your course today denys
investors equal access. Why should only an elite group in a democray
have access to this information? What about the concept of free markets
functioning best with open information? The more knowledgeablely open
our investment choices are the more clearly our people can choose how to
invest in the growth of our businesses, the direction of our ecomony.
Sheila Hoffses Marsh
Author: at Internet
Date: 04/22/2000 12:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Dear Sirs,
I would like to add my voice to those who have expressed their opinion about the
need
to open investment information to the individual investor. It is my belief that
each
investor should have all the available information in making a decision that
pertains to
the company that they may be or become a partial owner.
It is blatantly unfair to give information to a limited few, in the belief that
the greater
public is unable or unwilling to understand the information that leads to a good
investment decision.
Gill McDowell
Gill
Protect your PC with McAfee Clinic! http://www.mcafee.com/neoplanet
Author: at Internet
Date: 04/22/2000 12:49 AM
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TO: RULE-COMMENTS at 03SEC
CC: TMFMax@aol.com at Internet
Subject: Proposed Regulation FD
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Dear Sir/Madam:
The arguments against Proposed Regulation FD are not that "a little
knowledge can be dangerous" but rather "to many people with knowledge is
dangerous" and that the general public cannot assimilate, integrate and
effectively utilize "raw facts" about companies without it first being
digested and "reissued" by professional analysts who, in many cases, have a
conflict of interest in the success or failure of a particular company. I
think that we, the public, should be given the opportunity to make our own
decisions using the actual data as well as the opinions of "professionals"
and non-professionals. I strongly argue that this regulation fits in
perfectly with all of the other areas in which "freedom of information" has
been ruled to not only be necessary but a "right". I recommend, with maximum
enthiasim, your passage of this regulation.
Thank you for your consideration.
Sincerely, James F. McGinnis
708 Fox Hill Drive
Edmond, OK 73034
Author: "Karen Miller" at Internet
Date: 04/22/2000 5:40 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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While I realize that I might not be among the first to "hear" the company
news, I still believe I would learn of it faster if it were placed sooner in
the public domain rather than much later after an analyst had heard that
same news.
And if my analysis was faster and required less time to act on the
information learn, then my investment decisions would be much closer in time
with the analysts, rather than days or weeks later.
Milton Miller
Individual investor
Author: "Dave Milligan" at Internet
Date: 04/22/2000 5:39 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support proposed rule change currently under review by the Securities and
Exchange Commission (SEC) regarding the fair disclosure of information by
publicly traded companies to the public.
I flatly reject the arguments offered by the security analyst's special interest
groups that essentially maintain that they be allowed to be a legal institution
of financial high priests... for the good of the public involved in investing in
securities.
I wish to see open, immediate and fair access to all financial news released by
public traded companies.
I am a private citizen, without affiliation to any security investing company or
finanical advisement company.
I do stay abreast of these issues via the Internet and in the financial
newspapers.
Sincerely,
David Milligan
6054 Illahee Road
Bremerton, Wa 98311
Author: "Anomalous" at Internet
Date: 04/22/2000 12:50 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs:
I think the arguments put forth by the Securities Industry Association to
defeat the proposed regulation are ludicrous, insulting, and brazenly
demonstrative of their self interest and desire to prevent equal access to
new information from publicly traded companies. I resent the implication
that individual investors such as myself are incapable of making intelligent
decisions without the data first being filtered, evaluated, and interpreted
by these 'professionals', whose primary interest is generating commissions
from the quantity, not the quality, of stock transactions they make on
behalf of their clients.
Frankly, I am surprised this rule was not already in effect, or even
mandated by existing legislation. I thought the foundation of security
exchange was based on reducing or eliminating such insider or 'privileged'
access to relevant knowledge.
I strongly urge the adoption of the proposed regulation.
Regards,
Randy Morehouse
Author: "Luis M. Nieves" at Internet
Date: 04/22/2000 8:39 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hello!
I strongly recommend to move forward to this proposed regulation. Individual
investors are not just only people who decide to save some money by "betting" on
the market. Individual investors are owners of the companies we buy. As such,
company owners are not only interested in knowing what is really happening
inside the company, but are in the obligation of being alert and updated with
what the company is doing.
Individual investors must know the information as-is. Third party information
may contain data that will be strongly influenced by the "analysts". Depending
on whom the investors listen to, the information would be oriented toward what
that analyst think, obviously. However, if the individual investor have on hand
the same information that the analyst had, its investment decisions will be
informed and more sound.
Please continue with this effort to maintain us informed.
Thanks!!!
lmn
e-mail --- lmnieves@coqui.net
cell. -------(787) 612-7710
Home-----(787) 283-6016
Author: Jerry Oneill at Internet
Date: 04/22/2000 3:45 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom this concerns;
The rule to release information to the public, rather then discreetly to a
limited number of individuals should be affirmed for the simple reason that
only by full-disclosure of relevant information can the " insider-trading"
scheme be dwarfed. Also by open public disclose th efforts to regulate
market activity would be enhanced.
Thank you for your time
Jerry L. O'Neill
private investor and dedicated motley fool
Author: at Internet
Date: 04/22/2000 7:34 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs,
I, and every other individual investor with whom I have shared information
regarding the practices which have spawned the need for Regulation FD,
consider the position statement by the SIA to be a litany of transparently
self-serving distortions and blatant untruths. The essence of their
arguments tries to protect and justify an abuse of individual investors and
free markets; at least indirectly promoting a managed market volatility and
insider trading. Do these analysts expect the public to believe that the
fruit of their "labors"--one might consider it secret information--will be
equally available to institutions and the individual investors?
We call on the SEC to pass regulation FD forthwith.
Respectfully yours,
John C Owens
Author: "William Palermo" at Internet
Date: 04/22/2000 7:20 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File S7-31-99
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I am opposed to the censorship of the individual investor with regard to
public company information being first given to analysts. This is akin to
the fox guarding the hen house.
Certainly you are intelligent enough to realize there is a biased
opinion with regard to the issues their firms represent, as well as to
their largest accounts which receive this information first.
Is this the protection you are trying to afford us?
Thank you for your time.
Bill Palermo
Author: at Internet
Date: 04/22/2000 8:10 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:
It is with great dismay that I have read the comments from the SIA regarding
fair disclosure of information by publicly traded companies to the public. I
have always been a believer that honest people do not mind being audited, and
that is what this rule would essentially do. It would give us, the public, a
chance to share in the information that analysts may use to come to
conclusions. The most important reason for supporting this is so that we may
be able to more fully evaluate the analysts performance.
I think that the SIA's fears that this will diminish the role of the analyst
and send people running about making investment decisions based on
information they do not understand is rather unfounded. First, most
investors will not necessarily have the time or energy to examine most of
this material, they will still depend on analysts to interpret the
information for them. What this would do is give more investors access to
information that might contain pertinent questions for their analysts, making
their interchange much more meaningful. It is foolheardy to think that only
the analysts are able to decipher what questions their investors might want
to ask or should ask.
Another great benefit of this rule is that it would allow investors to better
evaluate and compare analysts, additionally it would take this small club and
expand it to other motivated individuals or groups. The SIA argues that a
few experts can better investigate information than a lot of underinformed
individuals. While this may have grains of truth, it is certainly my belief
that more experts may exist out there than have access to this information at
this time. By allowing greater access, more investigative truths can be
found and shared with the public. Limited access to information smacks of
the "old boys club" and allows too much room for corruption, fair and equal
access makes people compete out in the open and reduces the opportunities for
these abuses.
Thank you very much for your time and support of this regulation,
Bert Pickell
Boston, MA
Author: Craig Richards at Internet
Date: 04/22/2000 12:08 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hello:
Although I have not read the proposed regulation, I understand it is about
allowing fair access to company information by the general public as well
as stock analysts. It is my strongly held belief as an individual investor
that the current system of selective disclosure to analysts is grossly
unfair and makes a mockery of our capitalist system. Markets can only
function properly if people have confidence in them, and people will not
have confidence in a system that is not fair and equitable. Please do your
job and create a level playing field for all investors.
Regards,
Craig Richards
Author: at Internet
Date: 04/22/2000 9:15 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As an independent personal investor who has taken complete control of his own
investment decisions, I would like to strongly back the proposed SEC
legislation requiring all company information be disseminated to the public
and the analysts simultaneously. It is an affront to my intelligence to hear
that the brokerage community is expressing concern about giving company
information to the public without first being analyzed and "filtered" by the
analyst community. This appears to be a blatant attempt to protect a cozy
arrangement that has given the brokers "inside information" on a company that
is not readily available to the independent investor.
Recent market reaction and behavior has been the best illustrator of the
"intelligence" and "rationality" of the individual investor. While Wall
Street "experts" were selling huge blocks of stock and increasing market
volatility in a herd mode, the individual investor, by and large, stayed the
steady course and used common sense in the buying or selling of quality,
listed companies. Do the investing public a deserved favor. Enact the SEC
guidelines that will give ALL investors equal access to the information that
will best serve their investing decisions. Thank you.
Mark Ridder
15300 Windahm Court
Wichita, KS 67230
Author: James Rogers at Internet
Date: 04/22/2000 4:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
My experience with "analysts" and my own results lead me to trust myself
more than someone who will profit from churning my account, at my
expense both for taxes and transaction fees. If a company imparts
information to analysts ahead of me, or worse yet, instead of me, I
will tell everybody I know and never invest in that company again. I
insist on a level playing field, as mentioned in several important
documents, for example: The Constitution of the United States and the
Gettysburg Address.
My IQ is 141, I speak four languages and teach for a living. The high
school math required for investing is within my grasp. I am 58 years
old, and definitely not childish. And...most important....it's my money.
Not the analyst's money, my money. You can get away with a lot, but
never, never come between me and my money. Whoever gets the information
first in the stock market is the first pig at the trough, who eats his
fill and then lays down in the trough. Kindly remember who you work for,
on the government payroll. You work for the taxpayers (remember
"government of the people, by the people and for the people."????
James M. Rogers
Author: "herisau" at Internet
Date: 04/22/2000 8:02 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: analysts & public information
------------------------------- Message Contents
To Whom It May Concern,
The information an analyst puts out has value only when one knows WHO signs his
pay check. I have yet
to see negative information about a specific company from any analyst. My most
drastic example is the
former SAFESKIN CO. After finding nothing but high recommendations a new,
inexperienced investment
club bought some SFK stock. Within a month the stock price tanked and they lost
money on their very
first club investment. They learned to take ananlysts' recommendations with a
grain of salt. In the
interim, all members are now on-line and the stock researches are done on the
Internet. Analyst's
opinions? Yes, but only as a comparison to their own research.
Thanks for giving me the opportunity to express my opinion.
Leonie Sauer herisau@tir.com
Author: Walter Schaffhauser at Internet
Date: 04/22/2000 12:17 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen:
Re: Regulation FD: File No. S7-31-99
I agree with SEC Chairman Levitt and Bill Barker that the current system is not
only unfair to
individual investors, but it is bad for the markets as a whole. The ability of
companies to
selectively disclose material information to some sources, and to receive good
coverage as a result,
makes for a mockery of free flow of ideas and information.
I believe that the system, under which companies disclose timely information
important to the
individual investor, must be improved; and this proposed SEC regulation is
indeed a good and most
welcome start.
Individual investors (such as myself) deserve a level playing field.
I, therefore, urge you to adopt these new rules to combat selective disclosure
of information by
public companies, thereby establishing a basic principle of fairness which is
long overdue.
Sincerely,
Walter Schaffhauser
Individual Investor
Author: Mike Semcheski at Internet
Date: 04/22/2000 8:17 AM
Normal
TO: RULE-COMMENTS at 03SEC
CC: lobiondo@mail.house.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 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 (or positive!)
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,
Michael J. Semcheski
Ocean City, NJ
Author: "imtiaz@ComputerInstituteUsa.com" at Internet
Date: 04/22/2000 6:09 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
1) Is it true that "it hardly needs saying that analysts perform a necessary and
valuable function in the U.S. capital markets"? Is it true that to perform that
necessary and valuable function they need better information than the
participants in the market?
2) Is it true that, the "alternative model of millions of individual investors
and potential investors poring over prospectuses and periodic reports is highly
theoretical and out of sync with the real world"?
3) Is it true that analysts make the markets less volatile?
4) Is it true that analysts spend much of their time ferreting out negative
information about companies?
I think the investors need to be protected from the Analysts...
Regards
Imtiaz Seyal
Computer Institute
65 Route 4 East
River Edge
NJ 07661
Phone: 201 488 2255
Fax: 201 488 2253
imtiaz@ComputerInstituteUsa.com
Author: at Internet
Date: 04/22/2000 7:34 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
You may not believe it but most of investors are not really dumb and can
interpret information as well as the run of the mill analyst. Since most of
us are responsible for our pensions, why not put us on equal footing in this
investment world?
Capt. Don Stambaugh
Author: "pvsvoboda" at Internet
Date: 04/22/2000 1:00 AM
Normal
TO: RULE-COMMENTS at 03SEC
TO: "paul & vicki" at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To Whom It May Concern,
Re: Proposed Regulation FD - File No. S7-31-99
I am writing to comment on proposed Regulation FD and Securities Act Rule 181.
I heard about this proposed regulation from Bill Barker's commentary on the web
site www.fool.com. We as individual investors should have access to the same
information from companies at the same time as analyst and institutional
investors. Here are some excerpts from their letter to Jonathan G. Katz,
Secretary dated April 6, 2000 and some comments from myself. Their letter starts
"At the very beginning of the proposing Release, the Commission states that
"Information is the lifeblood of our securities markets." We agree. We believe
in the maximum flow of information from issuers, whether directly or through
securities analysts and the media, to the marketplace. We believe that in the
last two years there has been a significant increase in the flow of this
information. There are many reasons. Perhaps the most important is technology.
The Internet has given rise to both a widespread demand for more information and
an ability on the part of issuers to respond to that demand. The desire and
ability to make roadshows available more broadly over the Internet has met with
great demand for access to roadshows".
I agree with the above statement except the sentence that reads "We believe in
the maximum flow of information from issuers, whether directly or through
securities analysts and the media, to the marketplace". if you change this
sentence to read. We believe in the maximum flow of information from issuers
should be directly to the marketplace.
Another statement from their letter reads. "We believe that communications
between an issuer 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. In determining
whether to adopt Regulation FD, we believe the Commission should consider
seriously its adverse effect on issuers, analysts and the efficiency of the
marketplace".
Greater accuracy of market prices look at what has happened in the market during
the fourth quarter of 1999 and in the first quarter of 2000. Most of the analyst
were saying the NASDAQ stocks were overpriced. Qualcomm 1000.00 a share was one
analyst's prediction pre-split of course. And less volatility I believe you
remember April 4 and 14. Just a little drop.
Here is another statement. "Even if there is absolute theoretical compliance
with a Regulation FD, some will get the information and act on it sooner than
others. The investor who is watching the first screen on which the information
appears will have an advantage over the investor who is not watching but
receives a news alert signal regarding that issuer. Investors who instead of
working follow their stocks at the office will have an advantage, including
especially the ability to trade immediately in a more liquid market, over those
who wait until they get home from work. Investors monitoring electronic
communications will have an advantage over those who get the news over radio and
TV. And all the foregoing will have an advantage over those who get the news in
the next day's morning newspaper. In any event, the beneficiary of accidentally
disclosed material information would have an advantage over everyone until the
issuer makes public disclosure. If the issuer elects to meet the public
disclosure requirement by filing a Form 8-K instead of a press release, the
relative impacts are quite unpredictable because of the great disparity in the
ways and times in which information contained in Form 8-Ks finds its way into
the marketplace. If the Commission were to mandate disclosure by Form 8-K only,
this would ensure a disparity of disclosure".
I do agree with this statement. This is the way it works now except the analyst
gets the information before everybody else. If a form 8-k is used then that form
should be made available to all at the same time. One more statement I would
like to say something about is this one.
"It hardly needs saying that analysts perform a necessary and very valuable
function in the U.S. capital market. They, together with the media, are the
principal way in which important financially significant information (including
information contained in prospectuses and reports filed with the Commission)
effectively reaches most investors and gets reflected in the marketplace. The
alternative model of millions of individual investors and potential investors
poring over prospectuses and periodic reports is highly theoretical and out of
sync with the real world. 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. Yes,
they can elicit some facts, they can eliminate management "spin", they can bring
their expertise to the analysis, and they can give the markets rapid guidance as
to the significance of new information, thereby mitigating individual knee-jerk
reactions to specific information".
I believe that analyst and the media do perform an important and necessary
function for the U.S. capital markets they tell the individual investor where
the institutional investor wants us to put our money because we can't read or
comprehend those prospectuses or semi-annual reports that the companies put out
just to waste the trees, paper, ink, preparation time, and postage. Now I don't
think your as dumb as they think we are but let me remind you who they are.
"SIA brings together the shared interests of more than 740 securities firms to
accomplish common goals. SIA member-firms (including investment banks,
broker-dealers and mutual fund companies) are active in all U.S. and foreign
markets and in all phases of corporate and public finance. The U.S. securities
industry manages the accounts of more than 50 million investors directly and
tens of millions of investors indirectly through corporate, thrift and pension
plans. The industry generates more than $300 billion of revenues yearly in the
U.S. economy and employs more than 600,000 individuals".
I do want you to know I am one of the 50 million investors they describe above
but I don't believe they have my best interest at heart when they recommend to
you not to pass this proposed regulation. I could continue to pick apart their
letter but I think you understand what I am saying. I just want the same
information provided everybody else at the same time. It will be up to me to act
on this information if I so desire. There may be some unforeseen problems with
this proposed regulation but the current situation favors the analyst and the
institutions over the individual investor which in a roundabout way they are
investing the individuals money. I believe there is currently a lot of changes
being made in our society. With better educated and informed investors. With
more information being made available over the internet. I do believe this
proposed regulation should be passed. Thank you for reading my letter and the
opportunity for my voice to be heard over the internet.
sincerely,
Paul E.Svoboda
pvsvoboda@qwestinternet.
net
Author: Doug Tickner at Internet
Date: 04/22/2000 10:12 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File
------------------------------- Message Contents
My name is Douglas Tickner, and I'm an American citizen who is currently
residing in Saudi Arabia's Eastern Province.
One of the reasons given for sharing certain kinds of information only
with Wall St. analysts was that masses of individuals would not do as
good a job at ferreting out negative information about certain
companies. One writer on the subject, opposed to any change in the
status-quo, said that such a scenario was too highly theoretical and out
of sync with reality. It's not terribly surprising the writer would feel
this way since he is doing his best to appear objective in imagining a
future he is obviously opposed to. No wonder he finds it unrealistic.
What's out of sync is the way certain information about the market is
monopolized by a select few analysts. We as Americans have always held
that the free flow of information is critical to the health of a
democracy. Furthermore, the assumption that someone else is better placed
to know what's good for the rest of us is a paternalistic sort of
influence that's more in sync with European values than the ones that
have made our country great.
I urge you to put an end to this outdated practice of hoarding and
parcelling out information that hitherto has been the exclusive domain
of a few so-called analysts. Get with the program: borders are opening
up, barriers are coming down, information is flowing more freely than
ever before. And for the love of God, how many lessons do you need on
the value of transparency?
Author: "." at Internet
Date: 04/22/2000 7:14 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs,
I am writing in support of Proposed Regulation FD: File No. S7-31-99.
Selective disclosure is a disservice to small investors and gives unfair
advantage to Wall Street analysts.
This advantage seems to me to be similar to insider trading.
Please level the playing field.
Sincerely,
Matthew P Tierney
Author: Carl Tyer at Internet
Date: 04/22/2000 7:52 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I would like to make a comment on the above proposed rule. I am an
individual investor and do not use a broker. I make my own decisions
and manage my assets through a brokerage account with Charles Schwab.
I believe that full disclosure of information to "all" is the proper way
for the SEC to regulate information on publicly traded companies. Let
the individual make their own decisions about stocks with everyone
having access to information at the same time.
Freedom of information should be the rule.. there should not be
privileged "classes" of those receiving information.
Thank you for considering my opinion.
Carl L Tyer
Author: Bruce Whittall at Internet
Date: 04/22/2000 11:59 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION S7-31-99
------------------------------- Message Contents
Dear Sir/Madam,
Maintaining the current situation whereby information is only given to
the so called expert analysts to protect jo public is ridiculous. Please
help us all get in to the 21st century. We can look after our own money
these days, we do not need experts to tell us what to do with it. We do
however need the best information possible about companies. Such
information should be available to all.
Thank you.
Bruce Whittall
Author: "-" at Internet
Date: 04/22/2000 2:09 AM
Normal
TO: RULE-COMMENTS at 03SEC
CC: at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
I've just finished reading the SIA's argument against the above-listed
proposed regulation
and sirs, I am appalled. I am appalled that this organization thinks that we
individual
investors are too ignorant (or lazy) to analyze information coming out of a
conference call!
("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.")
The argument is made that open calls by a company could lead to "individual
knee-jerk
reactions to specific information". Has this been the case with companies
which already
broadcast live calls over the internet? Even a casual look at the graphs of
these companies
show that this is not the case. A more realistic reason for the SIA's
opposition to this regulation
is the fact that if this proposal is put into effect, it will level the
playing field for everyone,
making the old-world days of closed calls a thing of the past. It is
impossible to formulate a
rational argument that information available to ALL investors at the same
time is anything other
than fair, and thus, good for the market.
The 'con' argument worries about analysts having to ask questions in front
of each other, worries
that they won't ask the questions they should, "due to fierce competition
among analysts".
Sirs, I suggest to you that if a Wall Street analyst can not live up to the
expectations of his chosen
profession, perhaps he should choose another.
The SIA's statement against this regulation in one area argues that analysts
included in "private"
analyst meetings are virtual saints, slaying the dragon of volatility to
save us poor, uninformed,
uneducated investors. They imply that without their divine translation of
the facts handed down
to them, we would be ruined forever.
My dear friends at the SEC, I implore you, let us, the millions of
individual investors out here
prove them wrong...............
I urge passage of Proposed Regulation FD: File No. S7-31-99
Sincerely Yours,
Andrew C. Williams
Individual Investor
http://www.sec.gov/rules/0422b01.htm
