Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Wayne Abbott" at Internet
Date: 04/26/2000 8:28 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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I just wanted to encourage the SEC to stop selective disclosure to Wall
Street insiders. As an individual investor, I think it's incredibly unfair
that I don't have the same access to the same information to make my
investment decisions as a few select insiders. If this country is to have a
truly free market, selective disclosure has to be stopped. It's the right
thing to do and I implore you to do it.
Sincerely,
Wayne Abbott
Configuration Specialist, Expert Services
Siebel Systems, Inc.
11625 Rainwater Drive, Suite 500
Alpharetta, GA 30004
Phone: (678) 319-4605
Fax: (678) 319-4511
Email: wabbott@siebel.com
http://www.siebel.com/worldwide-services/ex_se.html
Author: Mike Adams at Internet
Date: 04/26/2000 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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Stop selective disclosure now!! Implement Regulation FD.
Michael E. Adams
Investor and Concerned Private Citizen
Author: "Kurt Alexander" at Internet
Date: 04/26/2000 10:53 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 that selective disclosure is not fair to the individual investor. It
gives those who are so informed an unfair advantage not shared by all. I
believe you should "level the playing field" and promulgate rules to forbid the
practice of selective disclosure.
Kurt Alexander
619 S. Rivera Lane
Yorktown, Indiana 47396
Author: "Neal S. Allen" at Internet
Date: 04/26/2000 11:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
It is long overdue to finally right the wrong of companies giving "selective
advance dissimenation" of important information to Wall Street Insiders/Analysts
without giving this news to the public at large, at the same time.
Selective disclosure of this nature has been, and is, a wrongul and shameful and
detestable practice that MUST stop now!
Your move to implement FAIR DISCLOSURE RULES FOR ALL of the investing public
will provide a move toward fairness in investing that should have happened years
ago.
You are to be applauded for finally doing what long should have been done.
Doing the right thing IS the right thing to do.
Thank you for your courage and vision to step up to the responsibility of seeing
that there is "fair" and "timely" dissimenation
for ALL.
Sincerely,
Neal S. Allen
nsa2@ij.net
Author: RG Alloway at Internet
Date: 04/26/2000 5:01 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 leveling the playing field.
Richard Alloway
521 Tall Oaks Dr.
Tillson NY 12486
Author: "Richard L. Aust" at Internet
Date: 04/26/2000 1:18 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 favor of the proposed regulation.
Richard L. Aust, P.E.
Vice President
Aqua Engineering, Inc.
Author: at Internet
Date: 04/26/2000 5:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99
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All information released by regulated companies should be made available
simultaneaously to all investors.
The SEC should protect the public from selective disclosure and prohibit such
practices.
Joseph Belflower
Orlando, Florida
Author: at Internet
Date: 04/26/2000 4:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Obviously, analysts who have information not available to investors at large
have a serious, unfair advantage which these analysts can sell to their
clients. I recommend that the SEC require all information on public
companies be freely available for all current and prospective investors.
James H. Brentzel
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Author: "David bergmann" at Internet
Date: 04/26/2000 6:59 PM
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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 giving information to a select few "analysts" is detrimental to
your strategy and the rules you enforce elsewhere to allow ALL investors to
have equal access to information.
You investigate, arrest and prosecute people for "insider trading" yet you
turn around and provide information to select individuals.
WHAT GIVES?????
David Bergmann
An Independent Investor.
Author: Don Bloye at Internet
Date: 04/26/2000 1:01 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg FD: File No S7-31-99
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Please believe that the American Investor has enough smarts to make rational
and realistic decisions, at least most of the time. Let Us Decide!
Don Bloye - investor
Author: "Bly; Brenda" at Internet
Date: 04/26/2000 6:33 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed regFD:file no s7-31-99
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I strongly support the Motley Fool's position on full disclosure. I am an
individual investor and feel that everyone should have full access to
whatever information is available. When institutions can speak privately
and with hold information , I feel it increases the likelihood of collusion
with analysts and big financial institutions. I hope my government supports
legislation that is in my best interests rather than big business'
A Tax Payer and a Voter .
Author: Brian Bochicchio at Internet
Date: 04/26/2000 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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>>>>
X-Sender: jfeldman@mail.hq.nasa.gov
Disposition-Notification-To: <
Date: Wed, 26 Apr 2000 15:06:32 -0400
To: bbochicc@hq.nasa.gov
From: "J. P. Feldmann" <
Subject: Proposed Regulation FD: File No. S7-31-99
send an e-mail like this one if you care....
use the same subject line.....
>Hello,
>I am in favor of full and open public disclosure of all financial
information....
>I am in favor of a "level Playing field"....
>Sincerely yours,
>Brian Bochicchio
>J.P. Feldmann - SAIC - Information Services Sector
Vienna, Virginia
voice: 703-442-5507 fax: 703-442-5310
Author: "Cathy & Carl J. Bourg Jr." at Internet
Date: 04/26/2000 10:21 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99" in the comment h
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As individual investors, my husband & I feel that we should be entitled to hear
information regarding the particulars of a company at the same time as the
analysts, etc. For Wall Street to oppose such an action clearly illustrates
their attitude of privilege that is so prevalent in their industry. They assume
they are intellectually superior to everyone else with the exception of those in
their click. Superior indeed...what a joke. The truth of the matter is that
they are beginning to realize that people are no longer dependent on them to
make decisions for their future investments. We have become a more sophisticated
society and are continuing to learn throughout our life time. In reality, it is
us who are of the superior intellect because we do not live in fear of the
possibility of others learning more than perhaps we ourselves know. It is our
belief that it is wrong to assume only certain masses are deserving of
privileged information. In America we stand against discrimination of any kind.
Perhaps those on Wall Street need to reassess the narrowness of their mind.
Sincerely,
Cathy & Carl J. Bourg Jr.
7060 Pinetop
Port Arthur, TX 77642
Author: "Michael Broad" at Internet
Date: 04/26/2000 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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I am an attorney and a registered investment advisor. I write to support
the SEC's proposed Fair Disclosure Regulation.
The United States has the world's best investment climate in part because it
has the fairest rules for investors. Americans and foreign investors are
attracted to US investments because the SEC has imposed and enforces
standards of fairness and honestly. The Fair Disclosure Regulations are
another step in this very positive direction.
My clients and I are mostly small investors, but collectively we and others
like us are a major force in American investments, and we deserve access to
the same information that is made available to the large professionals. The
proposed regulation implements existing law and shows good common sense as
well, and is to be commended.
Michael Broad
P.O. Box 307
Newtonville MA 02460
MichaelBroad@MediaOne.Net
Author: "Scott W. Brown" at Internet
Date: 04/26/2000 9:37 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 the SEC's efforts to ensure full and complete disclosure to all of the
owners of America's companies, regardless of the size of their equity holding. I
have read many of the posts that have already been received for this proposed
legislation, and notice, as I am sure you have that most of the posts that come
out against the legilation is the result of the individual author's lifelihood
being threatened. Our society has achieved the economic growth it has over the
past 200+ years only because we have continued to change, even though at times
this has caused certain segments of our economy to go through great upheavel.
For instance, alot of the adverse industry reaction to the Commission's proposal
is driven by concern over the informational role played by analysts at
broker-dealers. While I can respect the role played by analysts especially in
the past, when retail investors and issuers could not communicate directly,
these analysts played a critical role in disseminating information to the
market. However much like the horse and buggy and railroads gave way to the
Model T, with the advent of the Internet, this function of the analyst may at a
minimum be changing or quite possibly become obsolete. Today, as a retail
investor, I can obtain real-time information about issuers - over services such
as CNBC and CNNfn, or through personalized websites or automated emails which
deliver news about issuers I want to follow. Many issuers that conduct
investor-relations conference calls (by telephone or over the Internet) now
grant access to retail investors as well as analysts. In short, the value of the
role that analysts provide for me (and I beleive other long term buy and hold
investors like myself) is rapidly diminishing and in fact if the information
that they receive is first shared with their large clients (as prudent business
sense would indicate is the case) I am most likely harmed by lack of access to
this information. Analysts should not be allowed to profit on their ability to
gain unfair access to information that I, as an owner of that company, am not
able to also obtain at the exact same time. Selective disclosure has always
provided an advantage to certain analysts and investors, and I think most people
would agree this has eroded the credibility of the market place. WHile this has
always been unfair, there was no remedy. Again, with the internet, the remedy
has been provided. I would hope the Commissions goal would be to allow, to the
maximum extent possible, simultaneous equal access to all material news for all
investors. It would then be up to individual investors to determine for
themselves whether to receive that information directly, or wait for filtering
and interpretation by analysts or other intermediaries. A society is only as
free as the flow of information. Please allow the wonderful technological
innovations of the last ten years, to finally shine light in this dark corner of
the free market economy that has made this country the envy of the world.
Thank you for tackling this issue.
Scott W. Brown, CPA
Martinez, CA
Author: "cartellia m. bryant" at Internet
Date: 04/26/2000 8:07 PM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation fd:file no. s7-31-99
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Now is the time to end selective disclosure. with the advent of the
electronic age Wall Street no longer needs or should have this
advantage.
Cartellia Bryant
Author: "Len Budney" at Internet
Date: 04/26/2000 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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I am writing in strong support of the proposed regulation requiring
that financial information be distributed to all investors equally.
As an individual who must manage his own retirement savings, I am
harmed by the unfair advantage that selective disclosure gives to
``professional analysts''. Professional though they may be, they
do not have a special right to information above the rights of any
other interested party.
The Securities Industry Association has spoken against the proposed
regulation, arguing in part:
``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.''
In so saying, the SIA is confessing that professional analysts enjoy a
virtual monopoly on information, filtering it to the investing community.
They do not explain why they have a right to this special privilege;
why they deserve to function in this filtering capacity even without
the consent of the investing community as a whole.
The SIA makes two more unsupported claims for professional analysts:
``...contribute [to the market]...less volatility and, in general,
greater efficiency...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.''
First, why does a small cadre of privileged analysts produce a stabler
market? Very likely the opposite is true; the majority of investors,
believing that ``professional analysts'' are acting on privileged
information, will rush to imitate their investment decisions. Thus the
decisions of each of a very few individuals have an ``avalanche effect''
as large numbers of investors follow their lead.
Second, what is ``highly theoretical'' about investors making their
own decisions? The statement is thoroughly ridiculous. Today, some
investors make good decisions with help from analysts; some make good
decisions on their own, and many make very poor decisions. Depriving
investors of helpful information does nothing to improve the situation.
In conclusion, I am strongly opposed to the current situation, in
which certain professionals are conferred the unfair advantage of
inside information. Hence, I strongly support the proposed regulation.
Thank you,
Leonard R. Budney, Ph.D.
lbudney@pobox.com
Author: "jbtravel" at Internet
Date: 04/26/2000 5:40 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I want to be able to get the same information as those on Wall Street
this is the only way that is fare to all. Those who want the information should
have access to it
Sincerely
Jeff Buehler
Buehlertravel@hotmail.com
Author: "Callicott; Michael W POA02" at Internet
Date: 04/26/2000 10:54 AM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
CC: "Callicott; Michael W POA02" at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the proposed regulation FD: File No. S7-31-99.
Sincerely,
Mike Callicott
1111 G St Unit 1
Anchorage, Alaska 99501
Author: "Chris Carey" at Internet
Date: 04/26/2000 6:02 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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This regulation needs to be SUPPORTED and passed.
It is a COMMON SENSE regulation that removes what is
similar to pork-barrel-type-politics.....make the
playing field level for all investors.
Chris Carey
General Manager
Best Buy #264
Columbia, SC
Author: Tom Cibotti at Internet
Date: 04/26/2000 2:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Another small person urging you to strongly consider "Yes" for the proposed
Regulation
FD.
Fairness compels that it be passed without any "loose strings" attached.
Regards,
Tom Cibotti
Pres/CEO
Author: at Internet
Date: 04/26/2000 1:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Only recently I learned that corporations are able to release financial
information to financial analysts and brokerage houses without releasing the
same information to the general public. I was appalled that such a practice
takes place, let alone that it is legal!
But at least the SEC is now willing to consider banning the practice. In the
strongest way possible that I can express my position on this issue, I hope
that you will ban this practice of selective disclosure.
No doubt these Wall Street brokerage companies are spending millions in
lobbying efforts to keep this reprehensible advantage of theirs in tact. I
am nothing more than a private citizen who invests what little he can. There
is little that I can do in comparison with them. But I am writing this letter
in the hope that it might make a difference.
Especially in the financial world, knowledge is everything. In a free
society such as we are privileged to live in, how then can knowledge like
this be limited to a select group like this?? This is totally undemocratic
and should be made illegal.
Sincerely,
Tim Coyle
tcoylengbc@aol.com
Author: "Oklahoma Railroad Association; Inc." at Internet
Date: 04/26/2000 12:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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. The rule (Proposed Regulation FD) would require, among other things, that
companies no longer engage in the practice of discreetly disclosing important
information to Wall Street analysts without also giving that information to the
public at large.
I am for this rule. The public at large and shareholders should all be given
the same information as is disseminated to Wall Street analysts. There needs to
be a level playing field of what information the companies release.
It is not up to the Wall Street analysts to determine whether I or anyone else
is smart enought to understand the information released by any company.
Sheryl Creech
Author: Darliene at Internet
Date: 04/26/2000 8:24 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 favor the proposed rule change that will give all investors the
same information at the same time.
An independent investor,
Dirk Dekker
Author: at Internet
Date: 04/26/2000 6:04 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
As an investor, making my own decisions is an important part of my approach
to investing. I feel, based on my education, training, and life experiences
that I am fully capable of making a decision I can live with, PROVIDED that I
have the SAME INFORMATION THAT EVERYONE ELSE HAS in making their decisions.
In addition, I feel I have the right to receive this information AT THE SAME
TIME as everyone else receives it, otherwise I am at a distinct disadvantage,
not because of my ability, but strictly as a matter of preference as to
timing and dissemination. Our entire life style in the USA is changing for
the better when no preferences are shown. Life in "the Sunshine is Best".
Let us hope a preferential system is eliminated so that everyone has equal
knowledge at the same time.
Sincerely Yours,
Gerold F. Dixon,Jr.
16112 Armistead Lane
Odessa, Fl., 33556
813-920-5707
Author: "JAMES DONOHUE" <3NAZOO@prodigy.net> at Internet
Date: 04/26/2000 8:47 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:
We urge the above-mentioned proposed regulation be filed and legalized. We the
people, that are investing our personal monies into various companies' stocks
should have the right to know exactly what analysts have the right to know.
Maybe we won't want to read it all, maybe we won't understand it all, but what
all of us do understand is we have the same vested interests that brokers,
lawyers, and analysts have. It should be our choice to read such information so
it must be available to us as well.
We are long-term investors and feel that our retirement and future lies in the
hands of those who regulate and protect the people of America that includes the
little investor to the billionaire investor.
Thank you for your consideration.
James & Meg C. Donohue
20401-696 Soledad Canyon Road
Canyon Country CA 91351
3nazoo@prodigy.net
Author: "Durgin; David" at Internet
Date: 04/26/2000 3:35 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg FD File No. S7-31-99
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I am in support of this proposed rule. Its time to level the playing field.
Individual investors interests are not, if fact, best served by the
brokerage/analyst community at large.
Thank You.
David Durgin
c/o The Doctors Company
Napa, CA
Author: "Robin Edwards" at Internet
Date: 04/26/2000 9:49 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Information should be released to the puplic as freely as it is released to the
markets in order to maintain integrity and honesty within the system itself.
Failure to release information equaly will only promote an encrease in
fraudulant activties and would cost the public at large.
Ryan Edwards
Author: at Internet
Date: 04/26/2000 6:27 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 feel that I am entitled to the same
information as the "big guys", and insiders. Please level the playing
field and end selective disclosure.
Dean F Engle
Pearl City, HI
Author: "Randy Fenter" at Internet
Date: 04/26/2000 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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I disagree with the SIA's argument that individual investors are not
intelligent enough to make their own decisions about the value of securities
and need Wall Street's analysts to hear and interpret important information
first. I encourage you to change the present regulation.
Thank you,
Randy Fenter
302 Orchid Circle
Cedar Park, TX 78613
Author: at Internet
Date: 04/26/2000 4:12 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 am writing in response to your proposal on
discontinuing the average investor from receiving the same information as our
so called "wall street analyst." It is in my belief that the average
inverstor can and does make well informed decisions in regards to his/her
portfolio without the advice of these analyst. How better prepared are the
analyst who on average, only 10-20% beat the market index.
To disallow the people from making informed decisions
about their, retiremental income, their childrens college funds, their dream
homes, is truly an unfair decision.
Thank-you,
Michael W. La Flair
Author: at Internet
Date: 04/26/2000 11:50 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As a private investor I believe it is blatantly unfair to release important
information that significantly impacts my investment and retirement plans to
only an elite few.
Please approve the proposed SEC rule changes in this area.
Proposed Regulation FD: File No. S7-31-99
Ed Frenette
Owner: Online Equipment Liquidation
Author: Linda Godwin at Internet
Date: 04/26/2000 11:01 AM
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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 Linda Godwin and I am an active investor. I absolutely resent
the idea of giving brokers information while withholding it from the
public.
All information should and must be made public to all citizens. Such
protective
treatment of an exclusive group is an inappropriate use of public
records.
Do not let this happen.
Thank you,
Linda Godwin
2283 NW Maser Drive
Corvallis, OR 97330
Author: "Allen Green" at Internet
Date: 04/26/2000 3:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
The brokerage firms are given an unfair advantage over indivijual investors
now. Why should they have access to information before the public does? This
allows them to make insider deals and unfairly profit from this knowledge.
EVERYONE should have access to all information at the same time. That is only
fair. Thanks.
Allen Green
individual investor
Author: "Linda Grubbs" at Internet
Date: 04/26/2000 5:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD File number S7-31-99
------------------------------- Message Contents
I would like to voice my support for the proposed rule. I am firmly opposed to
selective disclosure.
Kenneth K. Grubbs
1429 Olde Forge Lane
Woodstock, GA 30189
Author: Guzman at Internet
Date: 04/26/2000 9:44 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File # s7-31-99
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I support the proposed regulation FD. As an individual investor, I
would like to have the fair disclosure of information on publicly traded
companies come to me, not filtered through a broker.
Thank you.
Robin Guzman
4128 Shadyglade Ave.
Studio City, CA 91604
Author: Marvin R Hamon at Internet
Date: 04/26/2000 9:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am an individual small investor and I would like to see everyone
receive information disclosed by companies at the same time. Selective
disclosure of information to Wall Street analysts is nothing more than
an invitation to insider trading by large investors. The small investor
receives the same information only after the more privileged investors
have already acted on it.
Sincerely,
Marvin Hamon
Author: "Hance; Tom" at Internet
Date: 04/26/2000 2:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Individual investors, such as myself, should be allowed to decide for
themselves whether they want the analysts interpretation or the full story
(or both). Requiring company information to be filtered by analysts is
unconstitutional and only aids in giving the analyst's firm an unfair
advantage. Please pass Proposed Regulation FD: File No. S7-31-99.
Thank you,
Concerned Investor
Thomas Hance
Author: at Internet
Date: 04/26/2000 4:39 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 for this regulation as all information should be available to all
investors. Bob Hansen
Author: "Trevor Hanson" at Internet
Date: 04/26/2000 11:04 PM
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TO: RULE-COMMENTS at 03SEC
CC: at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
This message is about the rule, proposed by the Securities and
Exchange Commission (SEC), "regarding the fair disclosure of
information by publicly traded companies to the public. The
rule (Proposed Regulation FD) would require, among other
things, that companies no longer engage in the practice of
discreetly disclosing important information to Wall Street
analysts without also giving that information to the public at
large." (per Bill Barker, The Motley Fool)
It is simply un-American to presume that the citizen-investor,
such as myself, armed with information from the public media,
is unable to draw intelligent conclusions about securities
trading.
Furthermore, even if we (the public) may sometimes draw
invalid conclusions, there is still no justification for
sustaining an oligarchic system in which elite specialists
are provided with inside information.
Based on evidence to date, these 'specialists' draw poor
conclusions, and following their advice is dangerous.
Are their earnings estimates better than 'the street'? Are
their BUY/HOLD/SELL recommendations reliable? (When is the
last time anybody saw a SELL recommendation?)
Give US, the citizen-investors, the primary data, and we'll
make our own decisions. The market makers and the institutional
investors may ride on and profit by the public marketplace,
but they are NOT the market. WE are the market.
Even we make bad decisions, at least our errors should not
be compounded by the legally sanctioned errors or vested
interests of specialists.
Public disclosure should be -- PUBLIC. This is common sense.
Disclosure to analysts is not public disclosure. Analyst
privileges are no different from conspiracy via a trust.
True, it's cheaper and easier for many companies to use
PR firms and circles of well-known analysts; disseminating
and defending information in the court of public opinion
is painful and difficult. But although analysts may offer
a route that is cheaper and easier, it's not a FAIR route.
We can't blame companies for using this route if it is
encouraged by statute and policy; but there is no reason
to encourage such behavior.
Level the playing field! Use the new tools that are enabled
by the Internet to establish a financial democracy! This is one
of the few opportunities in history, such as the creation
of the printing press, where a technical change can permit
the removal of an egregious social inequality, and strive
to provide all literate citizens with the same level of
access to the same data.
Please do not waste this opportunity! There are more
voters in the ranks of investors than in the ranks of
analysts!
Earnestly...
Trevor R. Hanson
Hanson-Smith, Ltd.
218 N. Jefferson St. #102
Chicago, Illinois 60661
=============================
Trevor R. Hanson
Author: "Harris; Terry" at Internet
Date: 04/26/2000 5:11 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I fully support Proposed Regulation FD: File No. S7-31-99, the rule that
requires that the public have access to the same disclosure of information
by publicly traded companies that Wall Street analysts have enjoyed. It is
my personal belief that brokers and analysts provide a valuable service, but
in many cases, their service benefits a small cadre of principal clients and
institutional investors. It is also my opinion that Joe Public is more
likely to buy and hold securities and is less likely to contribute to the
market volatility that results when institutional investors react with large
block sells and buys.
Thank you for the opportunity to be heard.
Terry Harris
Senior Director, I.S.T. Technologies and Architecture
De Lage Landen Financial Services
Author: at Internet
Date: 04/26/2000 6:00 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg. FD: File No. S7-31-99
------------------------------- Message Contents
Ladies & Gentlemen: the continued window dressing disclosure by entities
listed on stock exchanges is meant to paint a brighter picture so equity
sales support higher prices and appease investors who have paid inflated
prices for the holdings. A case in point is today's Amazon.com disclosure -
one release mentions a loss of $.35 per share for the quarter - $.01 better
than street estimates. Another indicates a $.90 per share loss for the
quarter after reflecting merger related costs. Generally accepted accounting
principals should be followed, forward looking earnings should be restricted.
Chaos will result if there are multiple accepted methods for "guilding the
lilly" - I'm still waiting to see positive earnings in a lot of the stocks
receiving the hype and am afraid of what the result will be for a great many
investors. The markets now look like a game of chance, moving on
misinformation and manipulation. I have always envisioned the SEC as
responsible for mantaining proper reporting in releases as well as all
financial reports. Jim Herte, CPA
Author: "Hester; John" at Internet
Date: 04/26/2000 11:25 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hello,
I find it highly inappropriate that any corporate information can be
selectively released to certain institutions, without it being disseminated
to the public as a whole. As a president of my own company, I try to make as
much information about the health of the company available to employees and
ALL investors, and feel that the public as a whole is not served by giving
certain individuals advanced notice in which to profit (or lock in their
profits) from corporate information.
John Hester
Techtricity Corporation
Author: Jack Hicks at Internet
Date: 04/26/2000 6:25 PM
Normal
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 do not believe analysts should be provided information privately that
is different from that which I receive publicly. I believe this lends an
unearned aura of knowledge to a pronouncement that is too often used to
curry favor with a corporation. The whole approach strikes me as
un-American.
John Hicks
8718 Linton Lane
Alexandria, VA 22308
Author: "organix" at Internet
Date: 04/26/2000 5:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Stop Selective Disclosure.
David Howard
Author: "Jason Hum" at Internet
Date: 04/26/2000 11:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Full disclosure for all investors. Wall Street should not receive
preferential treatment.
Jason Hum
915 - 7 King St East
Toronto, Ontario
CANADA M5C 3C5
Author: Sastry Isukapalli at Internet
Date: 04/26/2000 7:29 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hello,
My name is Sastry Isukapalli. I completely support allowing all
investors the information provided to analysts. The argument that
investors will harm themselves with such information is not valid
because I believe the new information will be taken in stride just
like the earnings reports and SEC filings. In fact, more analysts
would likely provide comments on such information in a way that would
benefit all investors, just not a select few.
Sincerely,
Sastry
Author: Colleen Janner at Internet
Date: 04/26/2000 10:42 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No.S7-31-99"
------------------------------- Message Contents
As an independent investor, I support the proposed changes the SEC is
planning in doing away with selective disclosure and providing equal
access to ALL investors, whether independent or through brokerages.
Colleen Janner
Author: Curt Johnson at Internet
Date: 04/26/2000 2:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
I submit this posting in support of proposed Regulation FD.
Let us suppose for a moment that the following four statements, generally
the basis of the comments by the SIA opposing promulgation of Regulation FD,
are true in all respects.
1. Analysts perform a necessary and valuable function in the U.S. capital
markets.
2. The alternative model of millions of individual investors and potential
investors poring over prospectuses and periodic reports ishighly theoretical
and out of sync with the real world.
3. Analysts make the markets less volatile.
4. Analysts spend much of their time ferreting out negative informationabout
companies.
I respectfully submit that any conclusion drawn from these four statements
that purports to establish that analysts need better information or more
timely information or more private information than other participants in
the market -- i.e., conscientious individual investors spending their own
money to become owners of companies -- is unsupportable and quite probably
incorrect.
In its comments to the SEC, the SIA notes "We believe in the maximum flow of
information from issuers, whether directly or through securities analysts
and the media, to the marketplace." I suspect there is universal agreement
on this overarching philosophical position. The SIA then quotes the SEC's
own materials, "... the federal securities laws do not generally require an
issuer to make public disclosure of all important corporate developments
when they occur. ... [I]n the absence of a specific duty to disclose, the
federal securities laws do not require an issuer to publicly disclose all
material events as soon as they occur." It then goes on to note that the SEC
proposes changing this long standing policy to "...subject an issuer to a
general obligation to make public disclosure of any material fact that it
discloses to any person outside the issuer ..."
Hear, hear!! I believe that is exactly what is proposed, the crux of the
debate. Can anyone, other than those with a vested economic interest in
maintaining the status quo, possibly make the case that rules developed and
promulgated 65 years ago -- in 1935, for Pete's sake -- to regulate what has
become a very different securities industry should not be critically
reevaluated and quite probably amended or modified?
Everyone agrees that information is the basis on which objective, critical
decisions about investments should be made. What is the advantage in
restricting its availability? To have analysts, bankers, brokers, and
lawyers protect us from ourselves? Who can realistically contend -- much
less prove -- that making information more available will lead to poorer
investment decisions? Who can support the position that corporate executives
have an obligation to speak to representative of some of its owners --
analysts employed by investment banks and brokerage houses -- and not to the
much broader group of its owners --individual holders of equity stakes? The
only potential problem, of course, is if executives are -- as suggested by
the SIA -- using private sessions with analysts to spin the facts or shade
the truth with a wink or grin or nod or gesture to protect their companies
or their personal positions. If that's the case, exposure to a broader base
of people with a range of knowledge and perspectives would be revealing and
embarrassing.
I cannot recall a comment in support of this proposed regulation that
suggests that communication by company executives be curtailed. No one wants
to eliminate the role of analysts, who provide a potentially valuable
service to a large segment of the investment community. No one wants to put
analysts out of work or close down their companies. What a growing number of
conscientious, intelligent investors suggest is that everyone should be
given the access to the same information at the same time. Broad access to
accurate information, as proposed in regulation FD, is the most equitable
way to provide all investors, big and small, individual and institutional,
the opportunity to make informed investment decisions -- decisions about how
they spend their money -- in the most timely manner.
Regards.
Curt Johnson
8509 Fauntlee Crest SW
Seattle, WA 98136-2534
mailto:CurtJ@fulcrum1.com
Author: at Internet
Date: 04/26/2000 11:25 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No.S7-31-99
------------------------------- Message Contents
Stop selective disclosure now!
It is really selective collusion to defraud the small investor.
Sincerely,
Brian Juntunen
http://www.sec.gov/rules/0426b02w.htm
