Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Michael Blain" at Internet
Date: 04/26/2000 8:44 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To all:
I don't usually go to the effort to write the government, but this is an
issue on which I feel very strongly. It is simply unfair that
representatives/analysts of institutional investment companies should have
priveledged access to company information before the legitimate shareholders.
Personally, I do my own homework when selecting a company to invest in and
expect to be there for a long time. It's a gross injustice to me personally
that all this effort could be in vain because what amounts to inside
information(which I believe is illegal) is being disseminated to others, who may
not even own shares in the company, before I have access to this information.
Like I mentioned earlier, this appears to be insider trading as I understand it.
I implore the SEC, as the regulator of free trade on Wall St., to end this
practice and make information available to ALL stockholders as it becomes
available without unfairly enriching a chosen few who are only looking to make a
quick $$ and the expense of smaller investors who truly believe in the companies
in which they invest and are proud of their positions as part owners of these
companies. I realize these chosen few have huge resources at their disposal
with which to influence public policy. Please don't let this happen and ensure
legislation protects everyone. I don't think anyone is asking for special
treatment here, just equal protection and access.
Thank you.
Michael Blain
Author: "Boone; Richard" at Internet
Date: 04/26/2000 9:39 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I highly recommend that the proposed regulation for fair disclosure be
passed.
Regards,
Richard Boone
Author: j brule at Internet
Date: 04/26/2000 6:52 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No S7-31-99
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Full disclosure is the only truly fair option for the American public.
James R. Brule
32912 4th Lane S
Federal Way, WA 98003
253-838-0624
xf8drvr@seanet.com
Author: at Internet
Date: 04/26/2000 10:14 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File No. S7-31-99
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We strongly oppose this regulation !!
C.F. Callison
C.F.C. Co. Inc
145 North ave
Hartland, wi 53029
Author: Harry Christensen at Internet
Date: 04/26/2000 9:04 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I woulk like to voice my support for this rule amendment.
Shareholders should have the same rights to access company information
as analysts.
Harry Christensen
Author: "Collins; Jonathan M" at Internet
Date: 04/26/2000 10:32 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Although I am subject to independence rules that prohibit me from investing
in most companies, I consider it a tragedy that a certain amount of
information is not required to be shared amongst shareholders and the public
in general. Please work to pass this important piece of legislation.
Jonathan Collins
KPMG Consulting, LLC
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Author: "Croser; Paul" at Internet
Date: 04/26/2000 10:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD - File No. S7-31-99
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April 26, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W., Stop 6-9
Washington, D.C. 20549
Re: Proposed Regulation FD - File No. S7-31-99
Dear Mr. Katz:
I believe the above-mentioned rule is a good one. I fully support it and
hope the SEC adopts it. It is a fair proposal for the individual investor.
Very truly yours,
Paul Croser
International Student Counselor
The Graduate School & University Center
The City University of New York
365 Fifth Avenue
New York, NY 10016
Tel: (212) 817-7490
Fax: (212) 817-1626
Author: "don ducey" at Internet
Date: 04/26/2000 10:44 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Re: Proposed Regulation FD: File No. S7-31-99
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 is
highly 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 information
about 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 accurte 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.
Donald. L. Ducey, Jr
2053 Farragut Drive
Stafford, VA 22554
Author: "Louis Eaglin" at Internet
Date: 04/26/2000 9:47 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Make the playing field fair for individual investors. Don't allow privileged
information only to analysts.
Louis Eaglin
1127 W. 111th Street
Chicago, IL 60643
leaglin@kiwi.dep.anl.gov
Author: "Kyle Edginton" at Internet
Date: 04/26/2000 8:06 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 writing to comment on the above file.
Simply put, I feel that the proposed rule of full corporate disclosure to
the public at large is a great idea. Comments that I have seen written by
the SIA (lobbying body for the full service brokerages) are laughable
arguments againts this rule. Their comment that analysts keep the market
volatility down is absurd. Of the approximately 10,000 mutual funds in the
States alone, almost 85% of these underperform the S&P500. When the end of
the quarter nears, these same analysts sell off what they have to take their
profits and the mass selling can move the market wildly. They do not
extract the information from management that the management does not want
them to know because the management actually knows what they should tell
them to ensure that they do not move their stock prices wildly. I have seen
cases where the news from a company in all positive and they still sell off
because they misinterpret that information. Thank you, but I think that I
am capable of making my own mistakes, and I am willing to take
responsiblilty for these mistakes. Unlike the analysts that make more money
by convincing the individual investors to trades in and out more often, thus
causing higher volatility. There is NO GOOD REASON not to implement the
proposed regulation on the public corporations. I applaud your efforts to
make this a reality.
Thank you,
Kyle G. Edginton
Nepean, Ontario, Canada
Author: "Caryl Erickson" at Internet
Date: 04/26/2000 6:31 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern,
I hope that you open up the information from companies so that it is
available to both analysts and the general public.
The current system favors the analyst's largest customers and institutions
over individual investors.
I do not feel that the change will harm the good analysts very much.
Already they have to compete against one another to interpret the data.
Their extensive education and the three year CFA exam somewhat assures them
of having an advantage over individual investors.
Additionally, because of their clout with large customers, they will
always be courted by companies thereby giving them the advantage of "seeing
and hearing" first hand more subtle observations that might give them
insight into how a company is doing.
Thank you,
Caryl Erickson
2825 Maplewood Circle East
Wayzata, MN 55391
Author: "J. P. Feldmann" at Internet
Date: 04/26/2000 9:54 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hello,
I am in favor of full and open public disclosure of all financial
information....
I am in favor of a "level Playing field"....
Sincerely yours,
John Peter Feldmann
Author: "sal ferrara" at Internet
Date: 04/26/2000 9:58 AM
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TO: RULE-COMMENTS at 03SEC
Subject: proposed reg. FD file No. S7-31-99
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SIRS:
I do not think it is YET time for BIG BROTHER to tell me what I can or can
not read.
I am against SELECTIVE disclosure of information. , ALL information,
Lets TRY to keep the playing field as level as possible.
S.M.Ferrara
Author: "Finnegan; Michael J. MAJ" at Internet
Date: 04/26/2000 11:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Michael J. and Mi Ra Finnegan
Small investors who want full disclosure
MAJ Michael J. Finnegan
Joint US Military Affairs Group-Korea
finneganm@usfk.korea.army.mil
DSN: 315-723-3179/3845/3298(FAX)
COM: 011-822-7913-3179/3845/3298(FAX)
MND: 900-7336/7337
Author: at Internet
Date: 04/26/2000 9:08 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an investor, I am befuddled by the Wall Street analysts view point that
individual investors should not be privy to the same information from
companies that they so-called experts receive. If analysts provided value to
investors, the analysts would not care one way or the other. However, the
fact is that the analysts, on the whole, do not provide value, thus the
reason for all the on-line discount brokers populating webspace these days.
Analysts make money by making trades. There is a huge conflict of interest
for analysts.
At any rate, if purchasing shares in a PUBLIC COMPANY is a practice, then
important news/information that affects those share holders should be made
public. Especially, now since many people do not use expensive brokerage
houses. It is a public company and, I believe, should have to make it's
information public, not privileged information.
Jerry Frazier, frazdog on TMF boards
Senior Buyer
Toyota Motor Sales, USA, Inc.
(310) 468-5111
Author: JOHN GANDOLFO at Internet
Date: 04/26/2000 7:12 AM
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
Immediate reporting for all is a good and vital policy shift.
John Gandolfo
Author: "Allen Hall" at Internet
Date: 04/26/2000 7:16 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern:
Although I am only a small investor, I don't need analysts to give me their
opinion in order to make a fact based decision. The price of a stock is a
reflection of all the information publicly known about that particular
company. Giving analysts, or anyone else, preferential treatment to private
information amounts to nothing more than insider trading. If I were given
such information and profited from it, I would be subject to SEC scrutiny
and discipline. Also, a generally accepted fact is that analysts tend to be
overly optimistic. This would seem to conflict with the SEC's view that
analysts ferret out negative information and then are supposed to pass along
a more accurate picture of the company to us, the individual investor. In
reality, you rarely get an accurate picture of a company from analysts
because of their excessive optimism and their vested interested in promoting
the stocks of companies they are holding.
Allen Hall
Author: at Internet
Date: 04/26/2000 10:29 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 most certainly in agreement with the SEC and fervently hope that this
proposed rule change will indeed pass.
Sincerely,
Jeanne S. Hertz
Author: "John Hooker" at Internet
Date: 04/26/2000 6:18 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD: File No. S7-31-99
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PLEASE PASS FAIR DISCLOSURE RULES. THANK YOU, JOHN HOOKER
Author: Anne-Marie Hunter at Internet
Date: 04/26/2000 8:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please vote to eliminate "selective disclosure" . ALL investors should have
available the same information.
Anne-Marie Hunter
Wang Government Services, Inc / Getronics.
Author: Jesse Hunter at Internet
Date: 04/26/2000 9:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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There should not be a separate disclosure of news and other
company information to analysts or institutional investors. All
disclosures regarding a publicly traded company should be
conducted via one of the many news wires so that everyone will
have equal and timely access to this information. There would
actually be lower cost to companies for doing this because there
would only be one news release as opposed to several. The only
down side for companies is that they can no longer use this
"inside information" to improve relationships with analysts and
therefore get favorable ratings.
Please change these rules so that everyone including the small
investor is playing with the same information and rules.
Thank you,
Jesse Hunter
695 W. Genesee Rd.
Baldwinsville, NY 13027
Author: Joe Juchno at Internet
Date: 04/26/2000 7:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Level the investment playing field and end the "good ol' boys" network.
Sincerely,
Joe Juchno
PacePros
Author: "Vivek Khanna" at Internet
Date: 04/26/2000 9:04 AM
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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, an individual investor, am outraged that current laws allow selective
disclosure of information to financial analysts. As part owner of companies,
I have a right to know anything and everything that the companies have to
disseminate about their business. Anything less, is in my opinion, a
criminal act against my faith in the company, and against the obligation
that the company has towards me since I invested my hard-earned money in
their company.
Please do not let the entrenched interests in the current scheme of things
to stall, or worse, totally stop this rule from coming into force. A rule
which I may add, extends the freedom of the average individual investor and
is just and fair. For after all, it is people like me, who are the force
behind this current bull-phase of the markets and the robust economy.
Please act in favor of freedom and fairness, not against entrenched
interests. Let this be another Boston Tea-Party!
Truly,
Vivek Khanna.
Author: Andrew Klemens at Internet
Date: 04/26/2000 9:28 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I have just a few points to make about the proposed Rule change:
I read an article written by the SIA in which they explained their reasons
for opposing the change in disclosure and have come to two conclusions:
1. If some investors are acting on the buy and sell commands of Wall Street,
under the new Regulation they will continue as they had before... but the
sell-off may be delayed by a day. It's not going to change their dependence
on analyst reviews.
2. The very name of the new regulation is substantial evidence for the
change and an admittance by the SEC that something needs to be done. If the
new provision will be Fair Disclosure, then our current method must be
unfair.
Sincerely,
Andrew D. Klemens
The Bentcil Company
1755 Midwest Blvd.
Indianapolis, IN
Author: Adam Kornick at Internet
Date: 04/26/2000 9:15 AM
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TO: RULE-COMMENTS at 03SEC
CC: Adam Kornick at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom It May Concern,
I am writing to comment on proposed legislation to require companies
to make equal and open disclosures. I wholeheartedly approve of this
proposal. Selective disclosures to institutional brokerages before or
in lieu of full public disclosure is unfair and creates an un-level
play field for individual investors. All investors deserve the same
opportunity to obtain information and it is the SEC's responsibility
to oversee this.
--
Adam Kornick
23 Montauk St.
East Falmouth, MA 02536
Author: "Steven LaFranchi" at Internet
Date: 04/26/2000 7:02 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I wish to state my support for the SEC proposal to ban selective disclosure
of material information and to clarify insider trading rules. It is unfair
for individual investors to lack information that is selectively provided to
brokers or other privileged businesses or individuals. If the securities
markets are to be fair and project an atmosphere of integrity and ethics
conducive to full participation of all parties; the information stream and
availability must be equal!
Sincerely
Steve LaFranchi
Author: Dave Lanaghen at Internet
Date: 04/26/2000 8:35 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor, I have long thought that the system whereby
analysts are given additional information not available to me as an
individual investor is flawed. There are several reasons for this.
Perhaps the biggest reason is that an analyst may not even be a
shareholder in the company. Analysts are quite often far from unbiased
and to give priviledged information to a group who can then use the
information for their personal gain at the expense of the public is not
a fair system.
I would encourage you to change this system and require that the same
information be made available to the general public.
David Lanaghen
145 Iroquois
Boulder, CO 80303
Author: michaelrlewis@webtv.net (Michael Lewis) at Internet
Date: 04/26/2000 8:45 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulaton FD: File No. S7-31-99
------------------------------- Message Contents
Stop selective disclosure.
Michael R. Lewis, Attorney at Law
Author: Joe Lyddon at Internet
Date: 04/26/2000 10:59 AM
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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 Vote yes for full disclosure to everyone at the SAME TIME.
Thank you,
Joe Lyddon (private citizen)
6879 Sard St.
Rancho Cucamonga, CA 91701
909-989-3673
Author: "Timothy Macke" at Internet
Date: 04/26/2000 8:36 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
It used to be that individuals relied on their brokers and analysts to learn
about, and make recommendations on, companies in which to invest. Could an
investor in New York be expected to know & have access to the detailed
financial information and sales outlook of Levi Strauss in San Francisco,
say circa 1900? At that time, the counseling provided to the far-away
investor by their broker could be invaluable.
Today, that information is available at the click of a mouse, instantly.
The financial services industry as a whole wants to retain their role as
information broker, because they can better influence their clients to
change their stakes in a company. This generates commissions & fees, wheras
a client merely maintaining their position in a company generates nothing
for the financial services firm. Since everybody has their own interests to
protect, let's reduce the number of people through which information must
travel before it gets to the final destination, the investor.
The financial services industry needs to change with the times. Information
is plentiful. Investors are largely educated and intelligent. The
financial services industry has its role and provides a valuable service,
but information broker shouldn't be one of them.
The proposed regulation would permit part owners of companies--investors--to
draw their own conclusions about a company's financial status and future
outlook at the SAME TIME as the financial services firms are making their
own assessments. The investor then only has to look past the spin put on
the information by the company itself, not try to decipher the motivations
of both the company AND the financial services analysts concurrently.
Fair Disclosure is what the investor wants. Please give us that choice.
***************************************************
Tim Macke
Nortel Signaling Solutions Group
Technical Services Operations
ESN 355-8031
919-905-8031
***************************************************
Author: silverfox at Internet
Date: 04/26/2000 11:13 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No S7-31-99
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It is about time that the general public is to receive the same
information as the
Wall Street insiders get (and at the same time).
Thank You
signed Alvin W. Madison
Author: "omanar" at Internet
Date: 04/26/2000 9:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
As an "owner" of several companies, I find it offensive that others can receive
information about "my" companies while I can not.
Otis Manar
Author: "Lazarus" at Internet
Date: 04/26/2000 5:48 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I vote for full disclosure
Randy McAtee
small pototoes
Author: Dennis Miller 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"
------------------------------- Message Contents
Selective dissemination of information by companies to favored analysts is
obviously not a fair system and leads to abuse in the marketplace. The
securities industry greatly underestimates the intelligence of individual
investors. The SEC should implement regulations that provide open and fair
disclosure to all.
Author: "Jim Moyer" at Internet
Date: 04/26/2000 8:17 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I would like this rule changed
Jim Moyer
160-B Calm Lake Circle
Rochester,New York 14612
Author: Chris Papas at Internet
Date: 04/26/2000 8:33 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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What does it mean that analysts might not downgrade a stock it is advising on
"strategic alternatives"?
--------------------------------------------------------------------------------
----
http://www.zdii.com/industry_list.asp?mode=news&doc_id=ZE503994
Despite an auditor's report questioning its viability, Drkoop.com's two primary
underwriters -- Bear Stearns and Chase H&Q -- were clinging to "buy" ratings
ahead of the company's latest diagnosis. Wit Capital, another Drkoop.com
underwriter, cut the stock to a "hold" April 3.
Will the underwriters finally be forced to downgrade Drkoop.com? Bear Stearns
couldn't comment on what it will do with Drkoop.com's rating -- it is advising
the company on "strategic alternatives." Would Bear Stearns really downgrade a
company it's trying to sell?
Chase H&Q analyst Stephen Fitzgibbons didn't return calls for comment.
Chris Papas
Technical Consultant
CHPS Consulting
518-426-4315
Author: "Tom and Sandra Paulley" at Internet
Date: 04/26/2000 8:00 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir/Ma'am,
It is absurd to not require simultaneous access to investor information to
financial analysts versus the public at large. I cannot imagine your position
will hold up to legal challenge.
Sandra Paulley
Author: "gwrhmr" at Internet
Date: 04/26/2000 8:20 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File no s7-31-99
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I strongly believe the average investor should have the same information any
analysis might be given in respect to the stocks. We are quite capable of
understanding that information. And in fact probably more capable than most
analysis.
Gerald W. Rees
Private investor
Author: at Internet
Date: 04/26/2000 8:35 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 for FAIR DISCLOSURE vs. selective disclosure.
Thank you for seriously considering this matter.
ADRIENNE ROBBINS
AROBB47863@aol.com
Author: Barbara Roemer at Internet
Date: 04/26/2000 7:38 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I strongly support the proposed regulation FD and look forward to the
investing public having information in a timely manner which is now provided
only to analysts.
Barbara Roemer
Individual Investor
Author: "Marshall Schofield" at Internet
Date: 04/26/2000 8:45 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Public companies should not be allowed to make selective disclosures to a select
group of individuals or companies. It is only fair, right and just that any
announcements made by a publicly owned company should be made to all interested
parties, not just a select few. Everyone who has invested or is considering
investing in these companies has an equal right to all available information.
To allow the companies to give information to one group over another should be
illegal and the company giving the information along with the individual or
company receiving the information should be guilty of fraud and punished
accordingly.
Marshall Schofield
PO Box 13559
Florence, SC 29504
msfield@netside.com
Author: 100523.2161@compuserve.com at Internet
Date: 04/26/2000 7:43 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
There is no justification for allowing select members of the population to
benefit financially from advance information. Many times I have read about
increased earnings, etc. only to find that someone had already acted on the
information in the market. This is not fair and should not be supported by the
SEC.
Rod Scott
Retired Caterpillar Inc.
Rod and Vicky Scott
Author: at Internet
Date: 04/26/2000 7:27 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD File No. S7-31-99
------------------------------- Message Contents
The technological advances, increase in individual investors
making their own decisions, and the efficiency of the market
demands the elimination of selective disclosure.
The argument that the elimination of "selective disclosure"
will cause issuers to withhold information is just
speculation. It is the self interest of most issuers to
disclose information because it has an affect on the price
of the stock in an efficient marketplace i.e.. more
uncertainty will equal lower stock price. Since most
executive compensation is tied to increasing investor value,
items that they have direct control over (the dissemination
of information) that can increase value will be performed.
Let the efficiency of the market work by elimination of
"selective disclosure" to a small number of special interest
individuals. If their analysis if of value, they can
demonstrate it by bringing "added value" to information that
is available to all. Not by being privy to private
information.
Level the playing field and let free and open competition
and the efficiency of the market work.
Derry P. Siers
Author: ray smith at Internet
Date: 04/26/2000 9:58 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Subj: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Date: 4/25/00 8:49:58 PM Eastern Daylight Time
From: R. Smith
To: rule-comments@sec.gov
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. A quick study of
past results would prove
that analysts are mostly wrong. They also are bias as the get paid
by the very firms that
have a vested interest in the buying and selling of stocks.
SIA desires unequal access to information by its members' analysts
because they resell the
information to the American public. But the information can be and
is colored by the vested
interest.
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.
Sincerely,
R. Smith
Author: "K. Steiger" at Internet
Date: 04/26/2000 9:38 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I support the proposed new regulation to provide equal access to information
to all investors. It's reasonable, it's ethical, and it's right.
Please know that you have my support in this matter.
Sincerely yours,
Ken Steiger
Author: Chris Stone at Internet
Date: 04/26/2000 8:29 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Sirs:
This regulation is not just the right thing to do, but is long overdue. In
a so-called 'information age', how could a case be made to hide information?
The comsumer benefits from the free flow of information in EVERY OTHER AREA of
our economy, so why not in the purchase of companies? An informed consumer is
a powerful consumer. We are the ones buying the stock, so we are the ones in
need of the company's numbers.
Please, do the right thing.
Chris Stone
Evergreen, CO
Author: "Wincelowicz; James" at Internet
Date: 04/26/2000 2:23 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am strongly in favor of improving the flow of information to the
individual investor.
The better companies already provide access to conference calls that others
limit to the professionals the analysts... Why? I've heard that it would be
disruptive or that the information would be over most people's heads.
Interesting. Well in my limited experience, it's better to hear the
information first hand - without a filter. And it's not the information
that's important it's the analysis of that information that's important. If
the Wall Street Types can't do a better job analysing the information than I
do, an amateur stock picker, leaving overseas without the luxury of easy
access to even CNN, I think they aren't worth the money their getting paid.
Good luck,
Jim Wincelowicz
LCDR, USN
Author: "David Winningham" at Internet
Date: 04/26/2000 9:56 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The SEC should by all means require companies to disclose information to
EVERYONE in the same manner. Why should the brokers, institutional investors,
etc. receive preferential treatment over anyone else? Is this a democracy or
what?
Dave Winningham
Author: "Richard Young" at Internet
Date: 04/26/2000 8:58 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen,
I am opposed to the selective disclosure of information to select individuals
prior to the release of the information to the public. It is unfair to provide
a select group this information so that they may benefit from it prior to
everyone else having access to the same information.
Sincerely
Richard Young, PE
Author: "Richard Young" at Internet
Date: 04/26/2000 8:54 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen,
I am opposed to selective disclosure of information to a select group of
individuals prior to an announcement to the public at large. Why in the world
would you allow something like that to happen?
I support release of information to the public as a whole and not to select
persons. To do otherwise would provide an unfair advantage to "inside
information".
http://www.sec.gov/rules/0426b03.htm
