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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: "RCBarto" at Internet Date: 04/27/2000 2:03 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Disclosure ------------------------------- Message Contents All investors should have access to the same information at the same time. Analysts getting special briefings is just inviting insider trading. As an investor I should have the same opportunity to buy well or sell well as anyone else. Cordially, R. Clark Barto, Investor

Author: at Internet Date: 04/27/2000 12:25 PM Normal TO: RULE-COMMENTS at 03SEC Subject: selective disclosure ------------------------------- Message Contents As a committed stockholder who trades regularly and does my DD I feel cheated not to have the information analysts are given that influence their decisions that I would not be privy to in a timely manner. SINCERELY, Mason Batchelder

Author: Rick Brooks at Internet Date: 04/27/2000 12:47 PM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: Regulation FD ------------------------------- Message Contents I strongly support the implementation of regulation FD. I am a candidate for Chartered Financial Analyst, a registered rep with the NASD (Series 7 and 66), and a representative for RunMoney.com. I believe that the current system of disclosures only to analysts is unfair and results in the perception of preferential treatment for large wall street firms. I am responding on my own behalf, not on behalf of my company. Sincerely, Rick Brooks Investment Advisor Representative RunMoney.com 858.509.9560 x136 rickb@runmoney.com

Author: "dick davis" at Internet Date: 04/27/2000 11:56 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation FD: File No. S7-31-90, Ellenar Associate ------------------------------- Message Contents Fairness should dictate public inclusion! Richard Davis

Author: at Internet Date: 04/27/2000 9:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: proposed reg fd: file no. 57-31-99 ------------------------------- Message Contents I am in favor of simultaneous news to the public at large... Thank you James H Davis P O Box 4693 Newark, DE 19715-4693

Author: Steven Destefano at Internet Date: 04/27/2000 11:29 AM Normal BCC: RULE-COMMENTS at 03SEC TO: rule-comments@sec.com at Internet Subject: Proposed Regulation FD: File No. 57-31-99 ------------------------------- Message Contents To whom it may concern: I am writing as a private citizen/investor. Please change the rules that currently allow companies to give important information to Wall Street analysts and large institutional investors without simultaneously giving the information to the public at large. It is grossly unfair that this situation should exist, and should be corrected. Sincerely, Steven A. DeStefano 10838 Sonora Ave Alta Loma, CA 91701

Author: "Sally Dillon" at Internet Date: 04/27/2000 7:14 PM Normal TO: RULE-COMMENTS at 03SEC Subject: file #57-31-99 ------------------------------- Message Contents 4/27/00 To Whom It May Concern: I am in full support of the proposed regulations to eliminate selective disclosure. I have had very bad experiences as a shareholder of Budget group, "symbol BD". The company has lost in excess of 85% of it's share value. There have been numerous times that I have witnessed the shares plummeting in price, only to discover missed earnings, additional losses or substantial restructuring charges, which were known to Wall Street, but not to me as an individual shareholder. This company is controlled by a select few who have "super voting" powers. I am trapped in my huge losses with no voice as a shareholder and no access to critical information on a timely basis. I hope you will consider the elimination of super voting shares, as well. Budget Group is an example of how these privileges are used to thwart the will of the shareholders. Regards, Sally Dillon 561-778-8388

Author: "Ad Dugan" at Internet Date: 04/27/2000 6:46 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Wall Street Information ------------------------------- Message Contents It has come to my attention that you will be voting on a rule tomorrow dealing with whether or not Wall Street can continue to "filter" information that it recieves about different companies. With the number of people with money in the stock market, it is inconceivable that there would be any rules in place that would allow information being kept from the public. There are a number of ways to trade on the stock market today. We do not all use brokers etc. to make our trades. If the public does not have access to all of the information available to make a wise investment decision, that is tilting the table unfairly. While some people may not use the information provided, if it isn't provided, then a decision is already been taken out of your hands. Sincerely, Ad Dugan

Author: at Internet Date: 04/27/2000 11:42 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Stop Selective Disclosure ------------------------------- Message Contents Proposed Regulation FD: File No. S7-31-99" Norma S. Gross

Author: "WALTER HUNNEL" at Internet Date: 04/27/2000 2:29 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S37-31-99 ------------------------------- Message Contents Sirs, If I am a shareholder, I should have access to current information being given to any outsider, other current shareholders, or potential shareholders. If I do not, the sharing of the information amounts to an attempt to manipulate the market for the advantage of a few at the expence of the many. Insider trading has been illegal for quite some time as it is a few, using information not available to others, to create an advantage for themselves. I see no difference, except for the number of people involved, between the current practice of providing "selected analysts" with information and classic "insider trading." If I am a person looking to purchase stock in a company, I feel I deserve to buy on accurate, current information, and at a price that reflects that information - not at some price set by "Market Makers" with information not available to the general public. I support legislation or rules to increase the availability of information, and do not support any legislation or rules that codifies the status quo or a reduction on openness required. Thank you. Walt Hunnel Lawrence Memorial Hospital Systems Administrator 785 840-2957 Pager # 830-5329

Author: "Buddy and Jean Hutchinson" at Internet Date: 04/27/2000 12:49 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Full disclosure ------------------------------- Message Contents I am a private investor that considers research to the key to my past and future investment success. Advise I have followed through on, on paper, has been 85 to 90% ineffective. Simply, I strongly support FULL DISCLOSURE to the investors and public, so we can make our own decisions with out analyses input, Those who want the analysis input can still utilize it based on their still forthcoming comments. Thank you for your attention to this information. Buddy Hutchinson

Author: Kenneth Luoto at Internet Date: 04/27/2000 5:20 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed RegulationFD: File No.S-7-31-99 ------------------------------- Message Contents As a stock market investor, I implore you to change regulation noted above to include disclosure of information to all interested individuals rather than just the selected Wall Street analysts as has been customary. Respectfully yours, Kenneth Luoto

Author: at Internet Date: 04/27/2000 3:14 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. 57-31-99 ------------------------------- Message Contents Please level the playing field William C Maag 407 Virgo Mission, Tx

Author: "swani mc Grath" at Internet Date: 04/27/2000 11:19 AM Normal TO: RULE-COMMENTS at 03SEC Subject: SEC Full Discloure Rules ------------------------------- Message Contents We must have full disclosure rules. I urge you to adopt them. Allen K. McGrath, Jr. M.D. ADOPT FULL DISCLOSURE

Author: at Internet Date: 04/27/2000 10:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation FD: File no. S7-31-93 ------------------------------- Message Contents I have previously written to support full disclosure, but, after hearing a spokesperson for the SIA this morning on National Public Radio, I wish to comment again. The SIA spokesperson said, in essence, that if a public corporation were to be required to make public to all what it makes public to analysts alone or, at least, to analysts first, they would stop disclosing any information other that that required by law or administrative regulation. His stated belief was that these publicly traded companies would be fearful that what they might say publicly might be information that "could move the market." Fearful of allegations of market manipulation, they would, upon advice of counsel, not say anything, not even to the analysts which would be detrimental to all investors on the presumption that universal non-release of information is bad for all investors. Somehow he failed to acknowledge the converse, that universal information release is good for all investors. Were publicly traded companies to remain mum, at least we individual investors and professional analysts would be on the same level playing field. The spokesperson for the IS, however, opined that information from publicly traded companies needs to be released privately to a select few, professional analysts, who can make sense of this information and wisely inform investors, presumably their clients. These may be the same professional analysts who had at least three day's advance notice that Abercrombie & Fitch was going to announce an earnings disappointment and, perish the thought, advised their clients to sell before everyone else found out. If the thoughtful, insightful analyses of these professional analysts add value to the information made available to all, then analysts will be rewarded in the marketplace. The marketplace rewards added value. As it stands, one cannot separate how much value is added by their thoughtful analyses and how much value is added, to a select few, by their advance and possibly insider information. Promulgate an even playing field policy. Let all information be released to all simultaneously. If analysts' analyses add value to information released to all, then they will be rewarded and this policy will not harm them. It will, however, help us individual investors who eschew the expensive opinions of professional analysts and full-service brokers in favor of acting on our own research and informed opinions. I urge you to grant us full, simultaneous access to information that is now, often, released to a privileged few. Promulgate a full disclosure policy. George W. Morrison 1075 N Hills Blvd, Suite 360 Reno, NV, 89506

Author: "rjreid" at Internet Date: 04/27/2000 5:21 PM Normal TO: RULE-COMMENTS at 03SEC Subject: change to rules ------------------------------- Message Contents Dear Sir, One can understand why Wall street analists want preferential treatment with regard to information. It is so they can be the first to buy when the news is good and the first to sell when the news is bad. This is tantamount to entrenching coruption in the financial services industry. It may be equated with insider trading. I don't think this is beneficial to the industry and will lead to distrust and unending litigation. Sincearly, Robert J. Reid

Author: Robert Sarao at Internet Date: 04/27/2000 4:37 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Let us hear.... ------------------------------- Message Contents To whom it may concern: I am opposed to the unfair rule of selective disclosure... As an independent investor I feel that I should be able to get any news concerning a company that anyone else gets. Without it, it is more or less discrimination on grounds of income, more or less... The large institutional investors get the upper hand already by being able to sway markets with with large portfolios... PLEASE KEEP SELECTIVE DISCLOSURE OUT OF THE STOCK MARKETS.... Thank you... Robert P. Sarao * * * * * * * * * * * * * * * * * * * * * * * * From the desk of: Robert P. Sarao 26 Ramgren Road Lunenburg, MA. 01462 Email: sarao@tiac.net * * * * * * * * * * * * * * * * * * * * * * * *

Author: at Internet Date: 04/27/2000 8:16 PM Normal TO: RULE-COMMENTS at 03SEC Subject: (no subject) ------------------------------- Message Contents " Proposed Reg. FD: File no. S7-331-99 " Let everyone know the correct facts about companies. It's the only fair way. Martha Staley

Author: "Ken & Rachel Staples" at Internet Date: 04/27/2000 10:39 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7=31-99" ------------------------------- Message Contents Proposed regulation should be open to everyone, not just a select few. We need a level playing field. Perhaps I would start investing if I had an equal chance instead to the analysts getting first shot to make the big bucks first. Ken Staples at kenrach@cybrquest.com

Author: "norm tucker" at Internet Date: 04/27/2000 1:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. St-31-99 ------------------------------- Message Contents We want this proposed regulation passed into law!!! Norm Tucker

Author: Veronica Valenti at Internet Date: 04/27/2000 8:52 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Public Disclosure Rules ------------------------------- Message Contents Please provide ruling requiring public companies to simultaneously make available all financial disclosures so that ALL investors have access to the same information at the same time. Thank you. Veronica C. Valenti

Author: at Internet Date: 04/27/2000 6:55 PM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: Full Disclosure ------------------------------- Message Contents Count me as another VOTER who will remember and speak out if this playing field is not leveled. Ron Young rdyoung@hotmail.com

Author: "Zaczkowski; Dan" at Internet Date: 04/27/2000 1:33 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective disclosure ------------------------------- Message Contents I am an investor against selective disclosure. Dan Zaczkowski