Comments on Proposed Rule:
Selective Disclosure and Insider
Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Henry Absher" at Internet
Date: 04/25/2000 3:14 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs:
As an experienced and successful individual investor, I strongly support
your efforts to level the playing field insofar as the release of financial
information is concerned. Despite Wall Street's and most companies'
opposition, I view their stated arguments in wishing selective
discrimination of information to continue as merely a smokescreen to
postpone the inevitable. Since I rarely use a full service broker to help
me make investment decisions, why shouldn't I have access to the same
information as they do at the same time they receive it. This is a matter
of equity and recognizing that today's electronic world makes this possible.
Despite the securities industry's efforts to hold on to customers by holding
itself out as the prime purveyors of financial information, the question is
when, not if, a level playing field will be effective. Why not make it
happen now?
Thank you for allowing my input into this matter.
Henry G Absher
Retired Partner, a Big Five accounting firm
Author: "Bonnie A. Baker" at Internet
Date: 04/25/2000 1:17 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Bonnie Baker
Twin Pines Realty
489 W. Flaming Gorge Way
Green River, WY 82935
Release all the information.
Author: at Internet
Date: 04/25/2000 3:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation File No. S7-31-99
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We definitely need a level playing field and individual investors should be
able to have the same information that analysts receive. Stop selective
disclosure. It is unfair, subject to manipulation and deception.
Carole Barnard
eloracpv@aool.com
Author: Lou Bedor at Internet
Date: 04/25/2000 1:58 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 support the Proposed Regulation FD: File No. S7-31-99.
Portions of my understanding and analysis follow. It is my
understanding that the newly proposed 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.
This sounds like a level playing field for a change. I am
sure that the arguments against this rule have two stated
bases: protecting the the individual investors (called the
public at large) and tradition. I am equally sure that both
sets of arguments are specious.
The first argument type is protecting the public/individual
investor. The arguments are that the public/individual
investor does not understand the complicated financial terms
and implications of public disclosure and that disclosure
might even make the market more volatile. To the first
argument, my response is three fold. First, if you don't
understand the events, you should not be investing. Second,
the market is a teacher. It punishes those who do not learn
by causing them the pain of loss of capital. Third, the
'Experts' do not now and never will guarantee their
recommendations.
The second argument type is tradition, It has always been
this way and the market has worked well because of it. My
question here is how does limited initial disclosure actually
differ from insider trading in any fashion than the legal
definition of insider trading. Tradition allows a few,
knowledgeable persons vs insiders, to profit greatly from the
early, restricted release of company and market information.
This would actually be acceptable to me if taxes where then
used to level the resultant playing field. But this is not
done. It is argued that the 'Experts' are necessary for the
market, that the public/individual investor cannot and does
not study the prospectuses and the quarterly reports, that
the 'Experts' find out the truth about the companies that
comprise the market.
If any of this is true, why is it that the 'Experts'
constantly tell investors to study the companies in which
they invest?. Why is it that the 'Experts' have no liability
for their expertise?
Louis D. Bedor
Author: at Internet
Date: 04/25/2000 3:16 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I would like to come down strongly in favor ot PROHIBITING SELECTIVE DISCLOSURE
of information to investment analysts without simultaneiously informing the
general public. In this day and age of on-line trading it is immoral and lacks
common sense to allow such a practice to continue. Given today's situation (not
a decade or two ago) such selective disclosure is nearly the same thing as
insider trading, and puts the general public at a huge disadvantage. It should
be illegal. Please make it so.
Bruce Bigelow
31 Scottsdale Drive
Hudson, NH 03051
Author: at Internet
Date: 04/25/2000 3:44 PM
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TO: RULE-COMMENTS at 03SEC
Subject: re: FD file no s7-31-99
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Since when do Wall Street analysts become god's chosen people. All investors
should be treated equally. Individual investors have become a huge force in
the market. I gave up being gauged by brokers 2 years ago. MY mutual funds
are stagnant while my individual portfolio has doubled. Please do not treat
us like children who cannot do there own research, I have worked very hard on
my own. Let us get the same info simultaneously. IT IS ONLY FAIR. Sandra
Bohn
Author: Randall Bowen at Internet
Date: 04/25/2000 12:33 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File
No. S7-31-99
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I support this proposed legislation.
Randall L. Bowen
Author: "Jeremy Clark" at Internet
Date: 04/25/2000 3:06 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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...ALL INVESTORS WERE CREATED EQUAL!! at lease all Americans were, so I think
this would apply here too. And since we are all created equal shouldn't we all
be treated equally? The fact that companies are not forced into full disclosure
is horrible. In this land of freedom and opportunity EVERY individual should
have the opportunity to make the money...not just a privileged few.
Sincerely,
Jeremy Clark
Investor
Taxpayer
Member of the US Military
What we obtain to cheap, we esteem to lightly... it would be strange indeed if
so celestial an article as FREEDOM should not be highly rated.
-Thomas Paine
Author: "David Felske" at Internet
Date: 04/25/2000 11:27 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Mr. Secretary:
In the land of the free, we are entitled to public information regarding public
traded securities as timely
as possible.
Investors are not second class citizens, entitled only to second hand, edited
and censored information.
I say, eliminate selective disclosure. Please vote in favor of the subject
regulation.
Thank You,
David Felske
Author: Thomas Furst at Internet
Date: 04/25/2000 12:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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To the Securities and Exchange Commission,
As an independent and private investor I would
like to support your recent Proposed Regulation
FD (Fair Disclosure). I believe that we should
all have access to information released by
publically-held companies at the same time. I
imagine as well that the companies would benefit
in only having to make one fair disclosure
instead of two.
I believe it is time to stop coddling securities
analysts and any Wall Street entity with the
guise of selective disclosure. Publically-held
companies should be responsive to the public that
supports them - to pander selective information
to selective groups only supports discrimination
and breeds ignorance.
Rock on SEC! Keep the system open!
Sincerely,
Thomas H. Furst
An Independent and Concerned Investor
Author: Tom Garland at Internet
Date: 04/25/2000 6:43 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 think that Proposed Regulation FD: File No. S7-31-99
should be adopted. Special perks such as selective
disclosure to a limited group of people give an unfair
advantage to them.
Sincerely,
Thomas E. Garland
8313 Shad Bush Ave.
Las Vegas, NV 89149
Author: "Ben Gillum" at Internet
Date: 04/25/2000 3:23 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 feel that the investing public should have access to any relevant
information about a company at the same time as any analysts get that
information.
Benjamin J. Gillum
Author: "kshalvorson" at Internet
Date: 04/25/2000 12:28 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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My impression as a non- investor who would like to be one: Having two sets
of disclosures, one for Wall Street and another for us peons out here,
simply fuels negative feelings I may have about government when I prefer to
feel otherwise. It's a let em eat cake attitude....Kent Halvorson, Modesto,
CA
Author: "dvharris" at Internet
Date: 04/25/2000 2:50 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 STRONGLY agree with the proposed rule, let's level the playing field to the
individual investors!
Sincerely,
Darrell Harris
Author: Hendry Tracy-P28610 at Internet
Date: 04/25/2000 11:35 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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In a few simple words... Selective Disclosure is wrong.
I am an individual investor, and an Analyst. No, I am not a Wall Street
Analyst by trade; in fact, I am a Software Engineer. However, I analyze
companies constantly. I analyze companies to determine potential
investments and to examine current investments. I am not too "stupid" to do
my own analysis of a company, and it is completely unfair for the Wall
Street Analyst community to assume that I need them to do my personal
investing work.
Because I do not need a "professional" analyst to interpret company news and
reports for me, I feel it is completely unfair for the "professionals" to
receive the news before I do. In fact, it is completely unfair for any
community or group to receive the "public" information before the rest of
the public. Selective Disclosure does not serve any purpose.
Please do not be swayed by the community of Analysts who are supposedly
"better" and "smarter" than the average investor. There is a mass community
of individual investors that feel strongly against the Selective Disclosure
process for the simple reasons: It is wrong and unnecessary.
Sincerely,
Tracy and Rebecca Hendry
1862 East Milky Way
Gilbert, AZ 85296
---------------------------------------------------------------------------
Tracy Hendry W: (480) 441-4990
Tracy.Hendry@motorola.com (Work)
the_hendrys@hotmail.com (Home)
Author: cliff howard at Internet
Date: 04/25/2000 3:46 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 am writing in support of the new regulation that would do away with
selective disclosure by companies to Wall Street Analysts. The SIA's
response that this new rule would make the market more volatile and that
the individual investor is unsophisticated enough to make his or her own
decisions based on the information they obtain when full disclosure occurs
is, at best, the same type of spin they fear that comapnies will engage in
if this rule becomes a reality and, at worst, disingenuous.
The market analysts that currently have the privilege of private
meetings
with company executives often make their money only when the unsuspecting
public makes a trade. In short, they make their living on the same
volatility that they claim to fear. The media worships the words that these
analyst use which have virtually no meaning like "outperform", "hold","buy
with a target price of", etc. These phrases and/or words are empty of any
meaning. They are thrown around after the analysts have had a "closed-door
meeting with executives of the company". For the SIA to claim that analysts
and the media make the market efficient and less volatile is completely
laughable. The market is becoming more efficient because individual
investors are now able to access information to make informed decisions
about the purchase of an individual stock. The information revolution that
is the internet has made it possible for an individual investor like me to
obtain the information necessary to make my own decisions about a stock. A
logical extension of this revolution is to allow the inidvidual investor to
obtain the same information that the analyst receive. Some companies have
already recognized this and are completely forthcoming with information to
anyone who is willing to access the information.
The SIA also claims that the analyst will not ask questions because it
might tip off their competition. The good analysts will continue to make
money because their clients know that they can trust them to do their job.
To not ask a question or pursue a line of questioning because I might be
listening is to shirk his or her responsibility to their client.
I did not get involved in the stock market other than through a mutual
fund because I did not trust the knowledge and or the motivation of
financial advisors who might encourage me to purchase a stock. The
information revolution has given me the information to make informed
decisions. The more information the better. I support the proposed rule
to make that information available to me.
Sincerely,
W. Cliff Howard
Rogers & Howard, LLC
Author: Sandra Kirkland at Internet
Date: 04/25/2000 11:44 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 an individual investor who supports ending selective information
disclosure by publicly traded companies to their institutional investors.
This practice is unfair to individual investors. Any argument that a
level playing field will lead to greater market volatility begs the
question of whether we have an open market system.
The stock market is inherently risky, and investors of all types must
learn to adjust their investment strategy to market realities. One of
those realities, however, should not be that information is legally
withheld from the most vulnerable segment of investors. The issue for
the SEC is assuring a level playing field. Ending selective disclosure
will further that goal.
Sandra Kirkland
Author: "Arun Kumar" at Internet
Date: 04/26/2000 1:31 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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No Selective Disclosures
Arun
Author: at Internet
Date: 04/25/2000 3:31 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 my opinion that companies must simultaneously give important news to
Wall Street analysts and the public at large.
Marilyn Leffler
private investor
Author: "ldl44" at Internet
Date: 04/25/2000 2:05 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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To be sure, my wife and I vote religiously. If the ordinary peson is not
put
on a level playing field with Wall Street, we will excercise our vote.
Thanking you in advance...Larry and Mary Letterman
Author: "Ben Livesay" at Internet
Date: 04/25/2000 2:59 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Prop. Reg FD: File No. S7-31-99
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I think it is insulting to the public to reason that only certain analysts can
read and understand reporting by companies. I am in favor of changing the reg.
to allow companies to selectively disclose info.
Ben Livesay
Author: Trevor Manser at Internet
Date: 04/25/2000 1:07 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Proposed Regulation FD: File No. S7-31-99
Great Idea - fairness to all!
IN FAVOR OF THE REGULATION - EVERYONE ON THE SAME PLAYING FIELD WITH THE
SAME INFO!
While you folks are at it, why not do the same for market maker info?
Or automatically enforce a maximum bid/ask spread amongst the makers?
They manipulate stocks all the time, for their own ends, in unfair ways to
the investor. A computer could do their job, if they don't want to do it.
Thanks for the Democratic Opinion opportunity.
Trevor B. Manser, TRW Layton Site Engineer
phone (801)774-3017 fax: (801)774-3088
mailto:Trevor.Manser@TRW.com
Author: "Markham; Gary W." at Internet
Date: 04/25/2000 2:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD: FILE NO. S7-31-99
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GENTLEMEN:
AS A SMALL INVESTOR, IT HAS ALWAYS BEEN A GREAT FRUSTRATION TO ME TO PUT UP
WITH THESE SO-CALLED "ANALYSTS", WHO ARE REALLY NOTHING MORE THAN INSIDER
TRADERS WITHOUT ANY RESTRICTIONS UPON THEM.
I VERY MUCH SUPPORT THE NEW PROPOSED SEC RULE CHANGES ON DISEMINATION OF
INFORMATION WHICH WOULS LEVEL THE PLAYING FIELS FO ALL INVESTORS.
BEST REGARDS,
GARY W. MARKHAM, P.E.
CHIEF OPERATING OFFICER
RIMKUS CONSULTING GROUP, INC
8 GREENWAY PLAZA - 5th FLOOR
HOUSTON, TEXAS 77046
713 621 3550 OFFICE
713 623 4357 FAX
713 302 4570 MOBILE
281 331 4570 HOME
Author: "James P Marquart" at Internet
Date: 04/25/2000 3:48 PM
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TO: RULE-COMMENTS at 03SEC
CC: "Michael R. Marquart" at Internet
CC: "Kirby W. Holladay; Jr." at Internet
CC: "jseale" at Internet
Subject: Proposed Regulation FD: File No. S7-31-99"
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Chairman Arthur Levitt:
I wish to support and encourage the SEC's actions in requiring full uniform
disclosures to all parties and members of the public, and thereby, in precluding
selective disclosures, avoiding the criticism of basic unfairness.
Best Wishes & Kindest Regards
Sincerely
Jim Marquart
Author: Donald Modell at Internet
Date: 04/25/2000 12:45 PM
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TO: RULE-COMMENTS at 03SEC
CC: chemfix@netscape.net at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC:
I would like to see Fair Disclosure to the Public at large on companies and
their performance.
Donald J. Modell
ABB Automation , INc.
Author: "Ron Oberheu" at Internet
Date: 04/25/2000 3:05 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:FileNo.S7-31-99
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I find it amazing that the SEC wants to keep information from individual
investors to "protect" the very people that rely on it for solid help. My
experience with analysts for over 5 years has been just like the commercial,
"The only one Broker, was me." I learned.
Analysts to me, are mostly a set up for turning money into their hands. Though
I do evaluate what they have to say and want to hear their words, I'm never sure
I can trust them. I also know if it was all bad, every one would see that, and
no one would invest money in this market at all. So yes analysts, do perform a
service.
There is far to much self interest in this world, to trust a group of people who
think they know best, when it come to other people's money.
Please search out your heart and minds for the LONG TERM GOOD of all men, not
just a few.
Please pass this Regulation.
Thank you,
Penguin Music Store #3
Owner Ronald Oberheu
Author: at Internet
Date: 04/25/2000 2:43 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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Dear sir .....
As a small state Registered Investment Advisor ... I favor full discloser to
all and not just few!
"Proposed Regulation FD: File No. S7-31-99"
North Star Financial Services
Girish Patel
Author: at Internet
Date: 04/25/2000 3:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD: file no.s7-31-99
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The current situation smacks of "insider trading". If I had that information
before the little investor had it you would tell me that I was violating a
slew of laws. Does
Wall Street have the right to do insider trading but I don't ? It's time to
refer to an important American document, "all men (and women) are created
equal".
As one of the financial TV programs stated: Beware of the 4T's: "Traders
talking to the traders" and then the little guy finds out!
Please pass: Proposed Regulation FD: File No. S7-31-99.
JOHN R. RACIK
2 KENNETH LANE
PARSIPPANY, NJ 07054
Author: "Robert Resendes" at Internet
Date: 04/25/2000 3:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Proposed Regulation FD: File No. S7-31-99
As "The Investor's Advocate" I can't see how the SEC can (effectively)
support institutional insider trading. Selective disclosure will only
erode investor confidence -- not help it.
Robert Resendes
Author: Dmitry Reznikov at Internet
Date: 04/25/2000 3:22 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I completely support the proposed deregulation of "priviledged"
information.
Every stockholder has a right to know as much as any financial analyst
about a company and its financials. Any argument that analysts are
"more intelligent" than regular investors or "are highly trained to
avoid market panic" are ridiculous. Priviledged information
distribution impedes free flow of information, of information that
should be free for every stockholder, and violates the very base
foundation of our free-market economy. Instead these analysts sell this
information for profit in form of reports in which they are supposedly
using every piece of knowledge known to these super-smart humans to
teach us, uneducated bums on how to spend our money and pay their hefty
fee in the process. 95% of all managed market funds underperformed
SP500. So 95% of those "analysts" even can't outperform a monkey that
throws a coin with "heads" indicating "market goes up" and "tails"
indicating "market goes down."
It is not my business how people make a living, if they want to sell
their analysis for money, who am I to say no to them, as long as they
sell their original work, not just information relayed from public
companies.
Or am I interpreting work "public" in the term "publicly traded company"
incorrectly?
Dmitry Reznikov
Cisco Systems, Inc
Author: John Ribble at Internet
Date: 04/25/2000 3:29 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 all for a level playing field. This is America isn't it? Why should
a select few be privy to important information. Saying that the general
public isn't smart enough, is the same as television producers using
laugh tracks because we're not smart enough to know when to laugh. Give
us some credit, we are not stupid.
John Ribble, just a" regular guy".
--
Visit the Guitar Nut at
http://www.geocities.com/Nashville/8379/index.html
Beer is proof that God loves us and wants us to be happy.
--Benjamin Franklin
Televangelists: The Pro Wrestlers of religion.
"The harder I work, the luckier I get." Thomas Edison
Advice
When someone annoys you, it takes 42 muscles to frown, but
only 4 muscles to extend your arm and whack them in the head.
Author: Michael Robey at Internet
Date: 04/25/2000 2:40 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 in fair disclosure. I also believe that those that stand
against it are indeed guilty of using insider information for a number
of unethical and potentially illegal activities.
Michael Robey
Author: "Jakub Rozga-JZ" at Internet
Date: 04/25/2000 3:19 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD, File No. S7-31-99
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I feel that every individual investor should see the same information. I am
appaled that
there is still such a degree of preferential treatment in the financial
industry. Please
pass this regulation. Isnt this what the "free" market is all about??
Jakub Rozga
1475 Edgewood 12H
Lima, OH 45705
Author: at Internet
Date: 04/25/2000 3:12 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To the SEC:
I am totally in favor of open disclosure. Selective disclosure places many
investors who do not use brokerage services at a distinct disadvantage. I
can not think of a single argument favoring selective disclosure that
overshadows the need for investors in an open market to have access to the
same information given to analysts.
David F. Sampsell
420 Welshwood, No. 47
Nashville, TN 37211
Author: "Sanchez; Arthur J" at Internet
Date: 04/25/2000 3:05 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I welcome an end to selective disclosures. If corporations wish to welcome
new investors, they should provide everyone the same information at the same
time. Otherwise, in order to compete, it will always be a question of
belonging to the "right" club or subscribing to the "right" services.
Arthur Sanchez
Author: Mark Sanford at Internet
Date: 04/25/2000 12:20 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Yes, level the playing field!
Mark Sanford
Software Engineer
Macromedia, Inc.
Author: "Andrew M. Shaw" at Internet
Date: 04/25/2000 3:21 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:
As an independent investor, I write in support of Proposed
Regulation FD to eliminate the practice of selective disclosure.
Contrary to the self-serving arguments of the SIA, it is by no
means clear "that analysts perform a necessary and very valuable
function in the U.S. capital market" through a privileged access
that allows them to "relentlessly pursue an independent line of
inquiry and ferret out negative information" about a company that
then "effectively reaches most investors and gets reflected in
the marketplace."
For if this were in fact the case, we might from time to time
see something other than "buy" or "hold" recommendations from
the analysts' employers.
As to the function of privileged information in providing
"greater accuracy of market prices, less volatility and, in
general, greater efficiency," this flies utterly in the face
of the accepted workings of a free and fair market. For buyer
and seller to agree fairly on the price of a security, there
can be no suspicion that one party is privy to undisclosed
information.
It is only natural that those who profit from selective access
to material information would claim that their gatekeeping is
in the public interest, that it promotes efficiency. Similar
claims have been made by the managers of now-defunct command
economies, defunct because, in fact, the self-serving claims
are false. The Invisible Hand works to promote the greatest
good through the actions of a multitude of free decisions --
not through the boosterism of "the few analysts" who are lobbying
against open access.
I urge that the selective disclosure of material information
be banned.
Sincerely,
Andrew M. Shaw
President
Adox Incorporated
--
Author: Smith Wayne-WWS002 at Internet
Date: 04/25/2000 2:56 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 represent two investors (my wife and myself). I have limited assets, a
wealth of time, and a wealth of information available through the internet.
I do not actively trade, and do not trade on margin that I cannot support
with immediate funds.
I feel all companies should be required to share all information with the
general public, rather than select analysts or primary shareholders.
Although my stake in a company may not be large, my partial ownership should
entitle me to information available to larger shareholders or analysts since
we all have the same thing at stake, our money. Partial disclosure should
be viewed the same as insider trading. In both cases, individuals are using
information not publicly available to try to make a profit.
The argument that individual investors are not capable of interpreting vital
information is weak in an open market. In an open, efficient market, any
inefficiencies will be resolved quickly.
I have taken control of my financial future by taking full control of my own
investing. I have outperformed the S&P500 index fund, a task 75% of all
actively managed mutual funds have not achieved despite the fact that they
are powered by analysts with private information. I take pride in my
ownership of the companies I own.
Thanks,
Wayne Smith
Author: "Mary Stadnika" at Internet
Date: 04/25/2000 2:57 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Of course life isn't fair, but that doesn't mean that it shouldn't be! COME
ON - GIVE US A BREAK!
Let us poor little guys have the same advantage all the rich big guys get.
What could make more sense?
ALL ANNOUNCEMENTS SHOULD GO PUBLIC - PERIOD.
Author: at Internet
Date: 04/25/2000 3:17 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs,
I would like to express my feelings about your proposed regulation. Why
should Wall Street insiders get information before the general public? It
only helps them to take advantage of the information faster than the small
investors. They already have many advantages over us small investors. Please
change the rules to level the playing field.
Thanks,
David Stevens
Author: itisme at Internet
Date: 04/25/2000 2:58 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Selective Disclosure - Proposed Regulation FD
Securities Act Release No. 7787, File No. S7-31-99
Dear Mr. Katz;
As an individual investor please give me one good reason why I should
not be able to see and hear information disclosed at the same time as
the big guys.. We deserve the same information. Try to be concerned
about the small investor and do the right thing.
Ralph Stork
Author: sully@pacinter.net (Sullivan; Edward) at Internet
Date: 04/25/2000 11:45 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File # S7-31-99
------------------------------- Message Contents
SEC:
please note that I am in favor of full disclosure
to all persons. I do not wish to depend upon the
possibly personal biases of Wall Street
"insiders" to decide what information I should
and should not have...and in what form I should
be provided with that information.
This is America. We believe in the free
circulation of information and ideas...after all,
that's how we came into being. We believe that
given accurate information, each person can make
a judgement in his/her own best interest. I do
not wish to be given information that is edited
to provide me with information that encourages a
judgement based on the possible best interest
of the information providor/editor.
Please arrange things so that I, and the
millions of investors like me, will have access
to all information in a timely manner so that we
may invest with full knowledge, insofar as it is
available at that time. I do not wish to be
taken care of, I wish to have full power to care
for myself and my loved ones. I trust the
financial wizards of wall street to have their
own best interests at heart. I trust you to
discern that they have been and will continue to
take care of themselves, not me and mine.
Edward Sullivan
Portland Oregon
Author: "michael thomas" at Internet
Date: 04/25/2000 2:00 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: file no. S7-31-99
------------------------------- Message Contents
The arguments given by analysts in favor of selective disclosure are selfish
and absurd. They merely wish to retain the financial advantages this
patently unfair practice provides them. They actually provide very little
useful service to the general public. Evidence of this can be found by
looking at the current ratio of buy/sell recommendations, as there are
almost no sell recommendations as this would hurt the investment banking arm
of their companies. The analysts use information from private conference
call to give themselves and their clients an unfair advantage, letting them
make informed trading moves before the info is available to everyone. They
are using this private info to benefit themselves only, not the markets at
large or the investing public.
Company information should be available to all investors at the same time,
so each can interpret the info for themselves.
Author: Torre Katherine-p53814 at Internet
Date: 04/25/2000 12:22 PM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Proposed Regulation FD: File No. S7-31-99
Definitely implement this regulation. Anything else, including claims that
individual investors are idiots by those Wall Street types would be and are
ridiculous. The saying "It takes one to know one" comes to mind.
Katherine Torre
Author: "Victor V. Vespertino" at Internet
Date: 04/25/2000 3:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen:
In so far as my taxes help pay for your product, I would appreciate
having equal access to it.
Sincerely, Victor V. Vespertino, Citizen, U.S.A.
Author: at Internet
Date: 04/25/2000 2:43 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: RE: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please support.
Thanks,
Carl Wambold
Author: "Terry Ward" at Internet
Date: 04/25/2000 2:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs: All information should be disclosed at the same time to any one
who is interested. Therefore, it is important to know what is going to be
disclosed before it happens and then give me, the consumer, the choice on
whether or not I want the information. Disclosing financial information to
a select few accomplishes not nothing more than promoting insider trading.
Terry Ward, Ph.D., ATP and
Executive Director
1020 East Lafayette Street, Suite 110
Tallahassee, FL 32301-4546
tward@faast.org
850-487-3278
850-487-2805 FAX
Author: "dan.m.whipple" at Internet
Date: 04/25/2000 2:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
RE: Proposed Regulation FD: File No. S7-31-99
Dear Sir or Madam,
As a shareholder, and thereby partial owner of several companies, I
respectfully request the same access to these corporations public documents
in the same timely manor that a broker or analysts receives them. To give
limited disclosure to a finite group of individuals is paramount to insider
trading. Allow each individual the option to choose based on an equal basis
of information.
Thank you for your time and consideration,
Dan Whipple, CCM
Author: Jacob Womelsdorff at Internet
Date: 04/25/2000 12:33 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As an shareholder (owner) of several publicly traded companies (I am also a
member of the public) I have the right to know what is happening in my company
at the same time these so-called analysts do. I personally would not buy stock
in a company that chooses selective disclosure.
There have been several milestones in the market's history. This is the next
logical step if we are to move forward as a truly free market system. Let us
level the playing field.
I do not need an analyst to "filter my information." I have never bought or sold
on any recommendation. I choose my future, and have had returns of 65%, 120% and
85% over the last 3 years without selective disclosure.
I understand this letter will probably have no effect on the outcome. Most
likely the Wall Street Lobbyists have won using their influence, but please do
the right thing and let the people invest on their own with free dissemination
of information.
Thank you for your attention,
Jacob Womelsdorff, Capitalist
Lake Elsinore, CA
http://www.sec.gov/rules/0425b07.htm
