Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Alafranji at Internet
Date: 04/25/2000 9:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please do not change the rules that currently allow companies to give important
information to Wall Street analysts without simultaneously giving the news to
the public at large.
Rafat Alafranji
2952 14th Street
Sacramento, CA 95818
Author: "JB" at Internet
Date: 04/25/2000 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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I have read the ideas expressed by the Securities Industry Association
lobbying on behalf of its full-service broker members. I completely disagree
with their contention that analysts provide a better service for the owners
of America's public companies by operating in an environment with access to
information denied to the very people who own or are considering owning
those companies. Their contentions betray all common sense.
If it betrays common sense, what is the motivation? SIA desires unequal
access to information by its members' analysts because they resell the
information to the American public. There's nothing wrong with reselling the
information. But making that information more valuable by giving them
unequal access to it, denying equal access to individual investors, is
wrong.
If there is any doubt in your mind that SIA's motivation is less than
honorable, be reminded of Merrill Lynch's contention expressed over a year
ago by its CEO that online trading was the worst thing for individual
investors. A year later and having reversed its thinking, Merrill Lynch is
now offering online trading to its customers. The contentions of the
community of full-service brokers expressed in SIA's filings show more
concern about the market share they are losing to the discount brokers than
concern for individual investors.
I strongly support Proposed Regulation FD.
--Dr. Jeff Ball
Author: "James Birdsall" at Internet
Date: 04/25/2000 11:21 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Let individual investors decide, not the 'analysts'.
James Birdsall
Orinda, CA USA
Author: Brian Bishop at Internet
Date: 04/25/2000 11:06 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please enact this regulation so that we all receive the same information at
the same time. Time is even more important than it used to be, and your role
is critical. Those with the most to lose will howl the loudest, and you can
hear from which direction this noise comes.
Brian Bishop
private investor
Author: "Fenske; Marla" at Internet
Date: 04/25/2000 10:06 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
I am a private investor and I believe fundamentally that corporate
information affecting shareholders should be freely distributed to any and
all concerned parties on an equal basis. The only reason Wall Street wants
a monopoly on this information (that is not theirs to begin with) is that
they use it to make money. It is not their information to own! Please do
the right thing for freedom of information and the individual investor.
Sincerely,
Marla Fenske
Seattle, WA
Author: "Fenske; Brian" at Internet
Date: 04/25/2000 10:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Proposed Regulation FD: File No. S7-31-99
I am a private investor and I believe fundamentally that corporate
information affecting shareholders should be freely distributed to any and
all concerned parties on an equal basis. The only reason Wall Street wants a
monopoly on this information (which is not theirs to begin with) is that
they use it to make money. It is not their information to own!
Please do the right thing for freedom of information and the individual
investor and support this regulation.
Sincerely,
Brian Fenske
Seattle, WA
Author: Thomas Guevara at Internet
Date: 04/25/2000 10:02 PM
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Receipt Requested
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 passage of this rule. As an individual
investor, who like many other investors are well-educated, I firmly believe that
I am capable of reading and properly analyzing any information provided by
America's companies.
The stock market is the closest market to pure capitalism, where the collective
information of investors allows for the most rational of decision making. Let's
keep it that way.
Thomas Guevara
Controller
City of Bloomington, IN
Author: Jeff Hall at Internet
Date: 04/25/2000 10:34 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 or Madam.
In my opinion there is no excuse for not giving the general public (i.e.
people like me) the same company financial information at the same time as
brokerage houses. The "protecting the public from itself" argument is just
too lame to condone. I urge you to change the rules and level the playing
field.
Sincerely,
Jeffery L. Hall
South Pasadena, CA
Author: Roy Higgs at Internet
Date: 04/25/2000 11:56 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99.
------------------------------- Message Contents
I have read the ideas expressed by the Securities Industry Association
lobbying on behalf of its full-service broker members. I completely disagree
with their contention that analysts provide a better service for the owners
of America's public companies by operating in an environment with access to
information denied to the very people who own or are considering owning
those companies. Their contentions betray all common sense.
If it betrays common sense, what is the motivation? SIA desires unequal
access to information by its members' analysts because they resell the
information to the American public. There's nothing wrong with reselling the
information. But making that information more valuable by giving them
unequal access to it, denying equal access to individual investors, is
wrong.
If there is any doubt in your mind that SIA's motivation is less than
honorable, be reminded of Merrill Lynch's contention expressed over a year
ago by its CEO that online trading was the worst thing for individual
investors. A year later and having reversed its thinking, Merrill Lynch is
now offering online trading to its customers. The contentions of the
community of full-service brokers expressed in SIA's filings show more
concern about the market share they are losing to the discount brokers than
concern for individual investors.
I applaud Proposed Regulation FD.
Roy Higgs
Author: wtj at Internet
Date: 04/25/2000 11:46 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 have just read the response to Release No. 33-7787 ("Release") by the
Ad Hoc Working Group on Proposed Regulation FD and the Legal and
Compliance Division of the Securities Industry Association ("SIA") on
behalf of SIA which was transmitted to:
Jonathan G. Katz, Secretary,
Securities and Exchange Commission,
450 Fifth Street, N.W., Stop 6-9,
Washington, D.C. 20549.
on April 6, 2000.
I have to say that I have rarely read such a blatantly self-serving
defence as this is of the "good-old-boy" network of so called analysts.
It repeatedly argues that select analysts and their large investor
friends continue to be given priviledged access to information issued by
corporations. The incestuous nature of this state of affairs has
exacerbated the rising cynicism of the large number of ordinary
investors who see corporate executives and the senior securities
industry employees extract a grossly disproportionate amount of income
from the profits generated by companies whose productive assets were
paid for by those ordinary investors.
It is my understanding that one of the main functions of the SEC is to
provide a level playing field for all investors in the marketplace. I
think this proposed regulation will go a long way to remove the robber
baron inhabited ivory towers that currently litter the landscape.
Sincerely,
-Wally Jansen
Author: stuart at Internet
Date: 04/25/2000 11:54 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 in support of the proposed regulation. Giving a select few access
to information only benefits the few who get the information first.
Thank you for your efforts to control selective disclosure.
Stuart Johnson
119 Meigs St. #7
Rochester, NY 14607
Author: "Gene Jones" at Internet
Date: 04/25/2000 11:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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I favor full public disclosure to all at the same time.
Eugene P Jones
Author: jon kip at Internet
Date: 04/25/2000 8:59 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99" i
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The present situation wherein some larger investment companies are given
important information about a company's news before the rest of us is
unfair to the average American investor and must come to an end as soon
as possible..
The Securities Industry Association believes that we, the average
investors, are too stupid to deal with the complete information about a
company. The SIA is just trying to justify its continued existance.
When the individual investor has the same information as the
"professional" analysts do, the market will stop being so manipulated
and might even settle down, as it is the "professionals" who make their
money by manufacturing the volitility...
WE don't need them.....and they are spending lots of money to convince
you that WE are too stupid to deal with information..
It isn't so...
jon kip
14348 Kittridge St.
Van Nuys, Ca
91405
Author: "Scott Lay" at Internet
Date: 04/25/2000 10:05 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 and a third year law student currently studying
the Securities and Exchange Act, I strongly support the Commission's
proposed regulation to ban selective disclosure of material information and
related efforts to reduce abuse of insider information. Widespread
dissemination of information is healthy for the markets, and likely will
reduce market volatility. The Securities Industry Association's
characterization of analysts as being much more able to digest information
than individual investors is a hasty generalization ignoring the large
number of individual investors who engage in due diligence on their own and
would find newly disclosed material information a valued resource.
Thank you for your consideration of my comments.
Scott M. Lay
2409 Halsey Circle
Davis, CA 95616
(530) 759-2232
Author: "Kim Leonard" at Internet
Date: 04/25/2000 10:32 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation - File No. S7-31-99
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Dear Mr. Katz,
I am writing to express my approval of the proposed regulation "Regulation
FD: File No. S7-31-99."
I started my own investment club with the foremost intent to educate
ourselves in investments. Over the years we have become quite knowledgable
about the Stock market and investing in general. As this is our retirement
fund, we have taken it seriously.
As the markets open up to more individual investors, thanks to the explosion
of on-line trading and self-service brokerage accounts, it is more important
than ever that information be allowed to flow freely and quickly among
market participants, to include individual investors. As an individual
investor, I have the majority of my retirement funds allocated to individual
stocks in my portfolio. In order to make the wisest decision possible, it's
vital that I have access to the same information at the same time as the
major brokerage firms' analysts do. Coupled with my own research (thanks to
the Edgar On-line system), earnings estimates and other information,
currently disclosed selectively by some companies, help me make the best
possible investing decision at that time.
Contrary to the SIA's belief that I am unable to make my own investing
decisions, I believe I have made some very wise decisions to date. However,
I also only invest in companies that currently do not participate in
selective disclosure. If your regulation is passed as proposed, I will have
a broader range of companies from which to choose, and for that I will be
grateful.
In the end, I believe the analysts will also profit. At present, I do not
pay much attention to analyst's ratings because many of them are only rating
the companies for whom they also make a market. This, in my opinion,
presents a large bias in favor of a "buy" or "strong buy" rating. If the
proposed regulation passes and the analysts are forced to add some extra
value to their research, I believe many people will start to pay more
attention to their analysis. The analysts who are first-to-market with
value-added research will be the clear winner, along with the investing
public at large.
I trust you will make the right decision and listen to the individual
investors.
Thank you,
Kim Leonard
Women's Investment Network
Denver, Colorado
Author: Tom Ludovise at Internet
Date: 04/25/2000 11:40 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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This is a good proposed regulation. No group should be allowed preferred
access to important company information. Shareholders should be allowed
equal and timely access to information vital to accurate decisionmaking.
Please implement the proposed regulation.
Tom Ludovise
Geolink Communications
Sebastopol, CA
Author: James Lummel at Internet
Date: 04/25/2000 11:18 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Since I handle all my stock purchase decisions myself, it is important that
I have access to the same information that for-hire stock analysts have. A
free market doesn't include some individuals getting exclusive access to
information.
James Lummel
jlummel@pacbell.net
Author: at Internet
Date: 04/25/2000 9:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Brook Adam Mancinelli
Firefighter/Paramedic
Moraga-Orinda Fire District
(925) 952-9116
In opposition to selective disclosure!
Author: "merkels" at Internet
Date: 04/25/2000 11:08 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please stop selective disclosure. Cliff Merkel
Author: "Krishna Nareddy" at Internet
Date: 04/25/2000 10:09 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please stop selective disclosure. It hurts small investors like me when
ANALysts get hot tips from company management.
Krishna Nareddy
Author: "Joe Paulus" at Internet
Date: 04/25/2000 10:43 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 or Madam:
I am writing in regard to the proposed fair disclosure rules. I beleive that
legislation preventing selective disclosure to only Wall Street analysts is
essential as part of our free market system. By allowing analysts priviledged
information, we have set up a system of essentially 'insider' trading, which
puts the small investor at a tremendous disadvantage.
Now that the stock market has become an investment mechanism available to ALL
investors, it is time to make the dissemination of the information to ALL
investors equal, regardless of their net worth or hierarchical positions.
PASS FAIR DISCLOSURE!!!
Joseph A. Paulus, Ph.D.
Author: Bruce Peterson at Internet
Date: 04/25/2000 9:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs:
I strongly support the these new regulations to require that public
information be made available to the public. By allowing companies to
disclose information to a select few, a distortion of the market occurs.
Ownership in publicly traded companies is becoming ever more widespread --
information crucial for making decisions about these companies should be
equally widespread.
Bruce Peterson
22904 NE 51st ST
Redmond, WA 98053
Author: "401Kicker.com" <401kicker@401kicker.com> at Internet
Date: 04/25/2000 9:09 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 or Madame:
I am an individual investor who does all of the research into the companies
that I invest in by myself. I was surprised to see that current regulations
allow companies to disclose financially "material" information to a selected
group of analysts and not have to share the same information publicly. I
would prefer to receive information directly from the company's management
and I don't need any analysts to digest the information for me.
The Ad Hoc Working Group on Proposed Regulation FD and the Legal and
Compliance Division of the Securities Industry Association ("SIA") stated
"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.
I would like to take exception to this statement. I have spent a great deal
of time reviewing 10k and 10q reports for companies that I have either
invested in or am considering investing in.
I recommend that the SEC adopt the proposed FD regulation. I believe that
this would be a positive move for all investors. The Internet allows
relatively more equal access to information to the investment community.
The Internet is also an economical way for companies to communicate with the
investment community.
Thank you for the opportunity to comment on this regulation.
Sincerely,
Philip Russell, Ph.D.
Secretary-Treasurer, 401Kicker, Inc.
http://www.401kicker.com
The Rules Have Changed.....Get Paid to Surf the Internet
http://www.alladvantage.com/go.asp?refid=GXL571
Author: Carl Rydbeck at Internet
Date: 04/25/2000 9:14 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Equal disclosure to the public as to Wall Street is important.
Carl Rydbeck Stanford, CA
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Carl Johan Rydbeck
crydbeck@stanford.edu or rydbeck@aol.com
http://www.stanford.edu/~crydbeck
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Author: "Ann and Wayne's work" at Internet
Date: 04/25/2000 10:23 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Disclosure should be made to all parties under the same rules.
Sincerely yours,
E. Wayne Scott
Author: Shaila & Narendra Shenoy at Internet
Date: 04/25/2000 11:07 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:
Dear Sir/Madam,
please consider this as a support for fair disclosure of information
by publicly
traded companies to the public. As an individual investor, I am upset
and angry
that a select few analysts have access to early information, when the
current medium
of the internet makes it possible for an even dissemination of
information. I do
not rely on analysts to ruminate and interpret data for me.
Regards
Narendra Shenoy
Author: david stefanovich at Internet
Date: 04/25/2000 9:55 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 an individual investor (blue collar worker-firefighter). I'm
investing in stocks so I can financially assist my six year old
daughter when she gets older. When researching a stock that i'm
interested in, I depend on information that is released to the press. I
feel this info has already been circulated to a select few that can
manipulate a market before I can make an informed decision on a
particular stock. Releasing information directly from the company to the
public would allow small investors to have an even playing field with
the select few that now receive information first.
Thank You and God Bless
David Stefanovich
Author: Robert Thornton at Internet
Date: 04/25/2000 11:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I thoroughly approve of the SEC's move to ban selective disclosure of
material information by public companies.
Robert M. Thornton
Private investor with no company affiliation
Author: David Tillotson at Internet
Date: 04/25/2000 8:59 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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"The Commission has become increasingly concerned about the growing incidence of
'selective disclosure' of material corporate information. In many reported
incidents, companies selectively disclosed important information -- such as
upcoming earnings figures -- in conference calls or meetings that are open only
to selected securities analysts and/or institutional investors, and which
exclude members of the public and the media."
I hope you follow through. It seems inevitable for a democratic society that teh
playing field be more level, that financial information will be more fairly
available to all investors eventually. We've come a long way since the turn of
the last century in making financial information available to the public. I
support your proposal to require fair disclosure of information.
David Tillotson
Employee of BP Exploration, Inc.
Author: jhwebbr@webtv.net (Jim Webber) at Internet
Date: 04/25/2000 11:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File no. S7-31-99
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This is a constructive change that's overdue . An important SEC function
is to provide open access to information you collect from American and
foreign companies. The SEC should not withhold any information from all
but select groups such as security analysts.
Discrimination of that kind can allow analysts to put their own "spin"
on company information that others cannot easily verify elsewhere in the
financial media. Some "analysts" might choose to "sit on" information
for their own purpose. if they knew the financial media might not have
access to it on a timely basis.
Please, let's go for this new proposed regulation! It'll be great to
have a new regulation that's a HELP!
Jim Webber
Author: "darryl.whitmore" at Internet
Date: 04/25/2000 11:06 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I'd just like to add my support to this proposed regulation. As a small
individual investor, I find it to be tremendously unfair that public companies
privately share information with stock "analysts." Public companies have a duty
to disclose information to their shareholders publicly, so that all shareholders
have the same opportunity to timely information that can impact their
investments.
Darryl G. Whitmore
http://www.sec.gov/rules/0425b12.htm
