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U.S. Securities and Exchange Commission

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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 ***************************************************************************** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. When addressed to our clients any opinions or advice contained in this email are subject to the terms and conditions expressed in the governing KPMG client engagement letter. *****************************************************************************


Author: "Croser; Paul" at Internet Date: 04/26/2000 10:51 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Re: Proposed Regulation FD - File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Re: Proposed Regulation FD: File No. S7-31-99 Dear 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: proposed reg. FD file No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Re: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents PLEASE PASS FAIR DISCLOSURE RULES. THANK YOU, JOHN HOOKER


Author: Anne-Marie Hunter at Internet Date: 04/26/2000 8:13 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 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, 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC CC: Adam Kornick at Internet Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal 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 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 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 Normal 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No S7-31-99 ------------------------------- Message Contents 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 Normal 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I vote for full disclosure Randy McAtee small pototoes


Author: Dennis Miller at Internet Date: 04/26/2000 4:29 PM Normal 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 Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File no s7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No.S7-31-99 ------------------------------- Message Contents 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 Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents 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


Modified:05/15/2000