Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "john anderson" at Internet
Date: 04/24/2000 9:48 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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Dear Jonathan G. Katz,
I would like to inform you of my position of why I strongly believe the SEC
should approve
the Fair Disclosure Act.
Individual investors rely on any type of newsource they can get about
publicly traded companies. Some information is biased, most information is
untimely, and some is flat out untrue. Arguements that support the idea that
individual investors can not think for themselves are grossly misleading.
Professional money managers argue that they filter out company information and
release thier judgement on company issues, playing an undelegated role as an
editor of information to the public at large. This type of disclosure
descrimintates against the individual investor, and prevents them from having
key information that only large financial institutions have. I do not believe
professional financial analysts weed out volitile information, but with the
media create large overvalueations in some industries, and companies
specifically, to control the US economy. To support this look at the large
internet technology selloff that had been grossly overvalued for months, and
fell sharply 10 months ago. To further support this I personally bought stock in
a company "financial analysts" believed to be a horrible investment.
1 year later Advanced Micro Devices (AMD) produces the worlds fastest computer
chips, has had spectacular growth, and the industry leader Intel (INTC) can not
keep up. One year ago Intel was forcasted as having a dominant hand in the
computer chip industry due to market hype and industry analysis of thier past
financial statements, not future prospects. Intel now can not fill the orders
they have taken, and can not keep up with industry developments.
As an investor of four years I saw that the "professional analysts" did not
forcast properly, and can not be relied upon by individual investors.
Individual investors do not even want analysts opinions, but instead
unmitigated, unbiased information about companies that are publicly held. If a
company is to be held by the public, it must recieve accurate information.
Individual investors rely on the SEC to make investing fair for all.
Thank you for your time and I hope the SEC will make decisions to aid individual
investors instead of favoring companies to prevent economic growth.
Sincerly,
John Ryan Anderson
University of Tennessee
Publicly traded companies should have to disclose any information they do to
Corporate Investors as they do individual investors. We can agree that both
invest with a profit motive, and that an individual company is no more important
than an individual investor. Clai
Author: Albert Braun at Internet
Date: 04/24/2000 11:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hi,
I support the move to make corporations disclose their results fully to
the public at large as early as they do to the secretive private
brokerages and other Wall Street firms. I'm all for the the new SEC
proposal on selective disclosure.
Best Regards
Albert Braun
714 Hampshire Street
San Francisco
Ca
94110
Author: Renee Chandler-Parsons at Internet
Date: 04/24/2000 11:28 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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I strongly urge the termination of the current policy of disclosing important
information to Wall street analysts without including the public at large. I
strongly support Proposed Regulation FD and consider this regulation vital and
representative of the country we live in. We the public make our own financial
decisions, and it is imperative that we have the right to the fair disclosure of
information by publicly traded companies that we invest in. It is an outrage
that the Securities Industry Association assumes we depend on their expertice
for guidance, when in fact, the public prefers to ignore their biased opinions.
The use of online brokers and educated investors has arrived, and with its
presence, the demise of full service brokers.
Author: "Gary A. Clement" at Internet
Date: 04/24/2000 9:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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Hi, I would like to voice my opinion on the above stated issue. I believe
that companies should divulge information publicly if they are going to
divulge information at all. If they don't, and they just release it to
certain persons on Wall Street, that is just a legal form of insider
information selling. This is the information age and everyone has the right
to that knowledge, not just the people that can afford lobbyists and bribes.
Thank you very much for allowing my voice to be heard.
Sincerely,
Gary A. Clement
Captain, United States Marine Corps
Author: at Internet
Date: 04/24/2000 10:41 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I'm for giving the public the same information as the Wall Street
Analysts.
Joe Cury
Author: "William Dittmann" at Internet
Date: 04/24/2000 11:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I find it rather ironic that the SIA is telling you that only by letting
important news filter through them can market stability can be maintained when
it is the institutional investors and programmed selling that cause the severe
fluctuations. What I think they are really trying to protect is their ability to
help there big investors and mutual funds out of a stock before the rest of the
market finds out the bad news. I work for a living, the only knee jerk reaction
I can do is to go to the bathroom. the members of the SIA will always react
faster than me but atleast this will level the playing field.
William Dittmann
Author: djfischer at Internet
Date: 04/24/2000 4:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Gentlemen:
This is to say I am in favor of Proposed Regulation FD: File No.
S7-31-99, which, as I understand it, seeks in part to stop the practice
whereby firms provide significant company information to selected
analysts, but not simultaneously to the general public.
I would also dispute certain comments made by The Ad Hoc Working Group
on Proposed Regulation FD and the Legal and Compliance Division of the
Securities Industry Association ("SIA") on April 6, 2000. The SIA's
claim 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" seems to me to
be contrary to current trends.
When I attended a high school reunion two years ago, many of my former
classmates (people are in their late 50's and early 60's) listed their
current occupation as managing their investments, and by that they
didn't mean they called a brokerage firm from time to time to get their
advice and have them place an order. They were actively engaging in
research themselves. While not all my classmates are doing this, more
than I expected are, and whether or not they all use it, those who do
need access to significant information as much as wall street analysts.
And note: these are my HIGH SCHOOL classmates. Among my college
classmates, this is likely to be even more prevalent.
I myself am more likely to trade on-line or through a discount broker
using my own research than I am to rely on a full service broker. Should
I wish to buy stock in a particular company, I would want all available
information to be available to me directly.
David J. Fischer
New Orleans, LA
Author: "Chris Heinlein" at Internet
Date: 04/24/2000 9:28 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 contributing to the advancement of a truly free, open and
democratic marketplace by proposing to require Fair Disclosure of material
corporate information. As an investor who believes that simple fairness can
only serve to strengthen our national and ultimately our global economy, I
strongly support Proposed Regulation FD. You are doing a remarkable job of
proving that government has an essential and irreplaceable role in assuring
that a "free market" can indeed be free, for the only free market is a
morally responsible market. Thank you for moving the US market in that
direction.
Sincerely,
Chris Heinlein
President and CEO
Heinlein Associates, Inc.
Founder of ITC and Synergis Inc.
Author: "Dan Hersey" at Internet
Date: 04/24/2000 11:16 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I think what you are trying to do is great! With the advent of online trading a
lot more individual investor are getting into the market. With the same data
Wall Street is getting it will give us the ability to make those wise investing
decisions without the need for the institutional investing (which I'm sure is
why the institutions are against this). Keep up the great work!!!!!
Dan Hersey
Investor
Author: "Ted Y Jones" at Internet
Date: 04/24/2000 9:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Re above subject; to heck with all the Wall Street lobbysts. Pls. end selective
disclosure to Wall Street analysts et al. Thank you, Ted Y Jones, retired.
Author: "J.P. Coleman Park" at Internet
Date: 04/24/2000 7:12 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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My name is Kristopher Lange and I wish not to have my rights to be hurt. It's
my opinion that Wal-Street and big corporations and banking agencies would
rather NOT have the small-investor to have any information. These agencies want
us to be scared to think for our selves!!! If this act passes, it will limit us
as investors even more. Please do not let this pass.
Kristopher Lange
3501 Shiloh Ridge Road
Corinth, MS 38834
Author: Jean Mac Donald at Internet
Date: 04/24/2000 1:14 AM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD:fileno.S7-31-99
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Wall Street should not have information that the individual investor
does not have access to. We study and make investment choices, as
private investors we should have the same information that Wall Street
has.
Author: David nordwick at Internet
Date: 04/24/2000 1:54 PM
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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 would like to simple state my support for
proposed regulation FD: File NO. S7-31-00. I believe it would help to
level the playing field
between the individual investor and Wall Street institutions.
Sincerely
David Nordwick
Author: "Fred Parker" at Internet
Date: 04/24/2000 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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FULL DISCLOSURE - YES!
F. Parker
Author: "Richard D. Perlman; M.D.;M.P.H.;F.A.C.S." at Internet
Date: 04/24/2000 9:21 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed reg S7-31-99
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Support!Thank you.
Richard D. Perlman
Author: William & BlendaPierce at Internet
Date: 04/24/2000 7:26 PM
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TO: RULE-COMMENTS at 03SEC
Subject: file s7-31-99
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these are public traded company's we are the public to withold
information
from any one makes this a one sided game and reminds me of Hitler
Author: "Feng Qian" at Internet
Date: 04/24/2000 11:36 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 would like to see information disclosed to
all...not just the big guys.. Everybody deserves the same information.
Feng Qian
Author: "Stephen Schneider" at Internet
Date: 04/24/2000 10:50 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC,
I am aghast that it might be considered acceptable to permit investment house
analysts to analyze and interpret security filings ahead of individual
investors. The collective record of investment house analyst reporting is
abysmal, and the evidence overwhelmingly suggests that analysts act in the
interest of their firms, rather than in the interest of current or prospective
shareholders.
Thus to allow analysts special privilege to filings, so as to "help" the
individual investor better understand what a company reports, does not
corroborate with what the media reports, and what any savvy individual investor
knows, about how investment analysts truly operate.
That the individual investor somehow benefits from selective corporate
disclosure to investment house analysts is a terribly misguided notion which
insults the intelligence of any thoughtful individual investor. Such disclosure
protects investment houses by serving to perpetuate a dependence by clients on
the analysts received disclosures. Thus the investment house, and not the
individual investor, is best served.
Sincerely,
Stephen D. Schneider
Individual Investor
Author: "Rajen J. Shah" at Internet
Date: 04/24/2000 10:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am writing to let you know that I am in full support of the action to
force companies to disclose the information that they give to analysts to
all the public so that it puts everyone on an even keel.
I for one don't like the idea of analysts and brokerages being privy to
information that should be public and accessible to everyone. It leads to
abuse of power and forces the average person to shell out money for the
privilege of having that information.
I also don't believe that analysts necessarily make markets less volatile.
On the contrary, with the internet business, there is considerably more
volatility because the analysts don't have much of a clue as to how to value
internet companies. I think the average person, such as myself, can do as
good a job, if not better, than what I have seen lately from the analysts.
Thank you.
Rajen Shah
A Moteley "Fool"
Author: "andy spix" at Internet
Date: 04/24/2000 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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The free trade of information is a foundation for true democracy. To treat a
small section of a public marketplace with exclusive rights for no reason save
tradition is paying homage to a feudal society harkening back to days of
barbarism. End Selective Disclosure.
Author: "Steven D. Splinter" at Internet
Date: 04/24/2000 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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I am writing in regard to the proposed regulation requiring public
disclosure of corporate information currently given only to select analysts.
I stronly support this regulation, and, contrary to some opinions I have
read, believe that it would decrease market volatility, as the "wisdom" of a
few select analysts would no longer be the only voice on such matters.
Thank you for your attention,
Steven Splinter
Author: Charles and Margaret Utt at Internet
Date: 04/24/2000 11:15 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD File No. S7-31-99 change
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The proposed rule change is welcomed by individual investors like us. I
don't know why a broker should have advantages and preferences to the
information available to him. Please continue with plans to change the
rules as proposed. Individual investors deserve to be able to have the same
access to information as anyone. Thank you for taking the time to read this.
Charles and Margaret Utt
Author: "Julieann Willes" at Internet
Date: 04/24/2000 11:58 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I believe it is important in this day and age that all information be
dissimanated equally to the everyone. The world is changing and with the
internet so has investing. The SEC needs to get with the NEW program and
realize that people are more involved than the "used" to be, and this
information should not be saved for a select few. Please take this into
consideration. Thank you.
Julieann Willes
http://www.sec.gov/rules/0424b07.htm