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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: Mary Akers at Internet Date: 04/27/2000 3:39 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear People at the SEC, Please do change the rules that currently allow companies to give important information to Wall Street analysts without simultaneously giving the news to the public at large. Mary Akers Mary Akers ww1013@worldweb.net


Author: "Anderson; Gary" at Internet Date: 04/27/2000 5:17 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Individual investors have every right to know all public information about the companies they own at the same time as any other investor--including institutions and analysts! The system is far too heavily stacked in favor of insiders. Gary Anderson


Author: Suzanne Bange at Internet Date: 04/27/2000 4:34 PM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents ..Please do the right thing for the small investor... Wall Street's policies have helped only big institutions in the past. Please put the power where it belongs, with the people. This is, after all, a democracy. Promote fairness in investing. There's only one moral, ethical choice to make. Please make that choice. Bart Bange average investor


Author: david f bartholomew at Internet Date: 04/27/2000 3:58 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am opposed to selective reporting by companies. They have already enough ways to obscure the relevant facts about managements actions and self rewards, as well as the health of the companies. It is completely wrong to allow companies to altogether withold information that may impact other people's descisions, financial resources, and even jobs. If anything, SEC regulations should demand even better disclosure with the bad news and questionable actions prominently reported. One thing that I have learned over the years is that companies (and management in particular) lie a lot! What's more, after working closely with many members of management. I learned that they pride themselves on making fools of other people and taking tremendous advantage of them. Please do not relax the reporting requirements of public companies. David Bartholomew 1236 Assumption Dr St. Louis, MO 63125


Author: Andy Baumer at Internet Date: 04/27/2000 3:31 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe the proposed regulation will benefit individual investors as well as improve the overall efficiency of the market. Many investors will continue to rely on member analysts of the SIA, but with the speed of distribution of information using the internet, those investors which seek the information will find it available immediately. The SIA's comments requesting denial of the proposed regulation show that they are only concerned with continuing their advantageous position. It is unbelievable that the SIA suggests that continuation of the existing system will "contribute to ... less volatility" given recent market swings. The proposed rule should be implemented as the immediate dispersal of information will result in a more efficient market. Andy Baumer 648 Adell Ave Idaho Falls, ID 83402


Author: at Internet Date: 04/27/2000 3:33 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No S7-31-99 ------------------------------- Message Contents Selective Disclosure is clearly morally wrong and unfair. Please end this ridiculous practice that benefits only the wealthiest and least vulnerable. An individual's dollar is just as much money as Corporate America's and much harder to come by. Peggy Berry


Author: at Internet Date: 04/27/2000 1:55 PM Normal TO: RULE-COMMENTS at 03SEC CC: Chad_Byersdorfer@cargill.com at Internet Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To whom it may concern: As I read the reaction that the Securities Industry Association had to the above stated proposed rule, I was shocked and insulted. As a personal investor, I believe that I am as qualified to make decisions concerning my personal finances better than anyone, due to the fact that I have my best interests at heart. If I may quote from their statement, "It hardly needs saying that analysts perform a necessary and very valuable function in the U.S. capital market. They, together with the media, are the principal way in which important financially significant information (including information contained in prospectuses and reports filed with the Commission) effectively reaches most investors and gets reflected in the marketplace. The alternative model of millions of individual investors and potential investors poring over prospectuses and periodic reports is highly theoretical and out of sync with the real world." Am I to believe that the SIA thinks that I am so ignorant that I cannot disseminate the 10-Q statements that are available free on the internet? Can I not tell when someone is telling me a lie? They are telling me that I cannot ferret out information from companies on my own behalf? The SIA speaks of "individual knee-jerk reactions to specific information". In my mind the SIA is the one with a collectively large knee-jerk reaction to the proposed rule. Why should they as analysists being the only ones privy to important information before the actual owners/stockholders of a company are informed? This rule is a long time in coming and definitely not "will undermine the great advantages of the current system" as the SIA states. I would urge the SEC to adopt this rule for the benefit of all individual investors. Sincerely Chad Byersdorfer


Author: at Internet Date: 04/27/2000 4:59 PM 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 I applaud the Commission for reviewing rules and regulations written 65 years ago and considering changes more adaptable to the Imformation Age. I support full disclosure and free flow of corporate business and financial information to ALL members of our society in a simultaneous and timely manner so we may make our own informed investment decisions. In this modern era of mass communications and intellegent investors, it makes no sense to perpetuate the limited flow of information to "insiders" and a selected elite few who may withhold or put their own biased spin on the information for whatever reasons. Elton W. Chase 2416 Wedgewood Dr. SE Olympia, WA 98501 E-mail: eltonchase@msn.com


Author: "JD Chong" at Internet Date: 04/27/2000 10:56 AM Normal TO: RULE-COMMENTS at 03SEC CC: at Internet Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I support your adoption of this proposed rule to make the playing field level for all who invest in America. Everyone should have the same information to invest or divest in a company, and it should be made available all at the same time. J JD CHONG 2100 3RD AVE APT 1605 SEATTLE WA 98121-2303


Author: Edward Clutter at Internet Date: 04/27/2000 4:45 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File Number S7-31-99 ------------------------------- Message Contents I am an individual investor. All news should be made available as fully and as completely as possible to all interested parties at the same time -- that includes us individual investors as well as the big Wall-Street firms. I am quite capable of making my own decisions, without the help of Wall-Street and I should not be put at a disadvantage just because I choose to go it alone. By the same token, information available to them should also be made available to me, so that my decisions, right or wrong, are base on all the current knowledge, not just a selected part. And I should not have to expect to pay for information that is not proprietary. Pass the regulation. Edward Clutter 1060 Northbrook Drive Aiken, SC 29805 ph 803 649-7087 Thanks


Author: Don Dansby at Internet Date: 04/27/2000 2:24 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am for equal disclosure of company information to ALL investors. Early disclosure to large investors should be illegal. That is the same as insiders trading on un-disclosed information. Don Dansby 2600 Lemmontree Lane Plano, TX 75074


Author: "Dave and Suzanne Delgado" at Internet Date: 04/27/2000 9:12 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Being an individual investor, I highly commend the SEC for your proposal to allow us to have the same timely access to information that the selective few receive. It is high time the selective disclosure granted solely to analysts comes to an end. I hope the new proposal, if passed, will level the playing field and allow everyone to invest with the same timely information. Thanks for the good work. Sincerely, David L. Delgado


Author: "Lynn Divoll" at Internet Date: 04/27/2000 2:22 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Many years ago the elite in the computer world assumed the general public wouldn't be able to effectively use "their" device and took no steps that would relinquish their hold. Then along came an individual who determined that was not the case, developed the software that allowed the general public access and the rest is history. Open the disclosure of information, deemed important enough to disclose to select individuals and organizations, to the general public. Surprisingly we might again be able to put it to good use. Lynn Divoll New Investor


Author: Matthew Faust at Internet Date: 04/27/2000 3:45 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Proposed Regulation FD: File No. S7-31-99 I'm for it. Matthew Faust


Author: at Internet Date: 04/27/2000 3:38 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regualation FD: S7-31-99 ------------------------------- Message Contents I am amazed that this legislation has even been proposed. I, and my compete are AGAINST it. Jerome O. Fitzmaurice, President jofitzmaurice & co 1840 Sequoia Avenue - Ste. 110 Burlingame, CA 94010-5353 Phone/Fax: 650-697-7695 e-mail: jofitz60@aol.com


Author: "Ford; Keith" at Internet Date: 04/27/2000 1:22 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Briefly, I would like to express my support for your proposed rule prohibiting selective disclosure and expressing my outrage that it was ever permitted. I If I am to have confidence in the market, I should not have to worry that someone else has access to information while I do not at the same time as the company claims it is disclosing the information. thank you. Keith Ford


Author: Neal Goman at Internet Date: 04/27/2000 1:39 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Sirs, I have been watching, listening, and reading the debate regarding FD. I am sure you have received many eloquent responses regarding the pros and cons of this proposal but I feel I need to express my views. I am an individual investor and a member of an investment club in Minneapolis, MN. I regard myself as a long term buy and hold investor. I resent the SIA's contention that I, with my "knee-jerk reactions to specific information", am the reason for market volatility. I seem to remember that the market downturn of Oct. 1998 was attributed to the institutional investors while the small investors held the course and didn't lose confidence in market. The number of mutual funds that have a turnover in excess of 100% contribute more to market volatility than any small investor. SIA believes that companies do not provide, in their SEC required filings, complete information needed to make investment decisions. It is only tenacious ferreting in face-to-face meetings by a few analysts that will bring this information into the marketplace. If this is true then let's amend the filing requirements (not something I think is needed, but that may be a future debate). SIA believes that it is the competition between independent analysts that allows for the possibility of complete disclosure. It is their desire to get the most information to their clients and beating the completion to the punch that drives the analysts. In the real world, analysts are not independent. They work for brokerage firms. Firms with large financial interests in doing business with the companies being favorably reviewed. Firms with large financial interests in getting investments to change hands. If anyone is to be objective about information in the market it is more likely to be the independent media than employees of a brokerage house. SIA believes that efficiencies can only be accomplished when a few are privy to information of interest to the entire market. This is insider trading as far as I am concerned. It allows one segment of the market to have an advantage and that does not make for an efficient market. Sincerely, Neal Goman


Author: "FGurwin" at Internet Date: 04/27/2000 4:08 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No. S7-31-99 ------------------------------- Message Contents Those of us that own stocks have the right to know the same news that analysts get early on. Oftentimes, the analysts work for stock brokerage firms that seem to make money on knowing news before anyone else. How easy it is to have their clients sell or buy before the analyst makes his "educated" comments which have such important effects on the market. I have watched analysts make those remarks and then seen the market react on it. Let's even the playing field and give the important information to those of us who have an interest in the market, too. A few should not have an edge over the rest of us. If there is something important to tell us---then tell us ALL! Talk about insider trading! WOW! Florence Gurwin


Author: Jim Healy at Internet Date: 04/27/2000 10:59 AM Normal TO: RULE-COMMENTS at 03SEC CC: "'tmfmax@aol.com'" at Internet Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Gentlemen: I would submit that individual investors need and deserve equal access to information along with the Wall Street stock touts/manipulators ("Analysts"). In a world where 95+% of the companies followed by Analysts have a "buy" or better rating, do you really think that Wall Street is a credible source of information for investors, as they claim to be? Most companies are downgraded (to a buy, accumulate or hold, never a sell) only after mangement issues earnings warnings, discloses fraud, etc. Which Analysts are those who are ferreting out this information beforehand? Which would have the courage to disclose such information given the resulting loss of underwriting and advisory fees for their institution and hit to their own pocketbook? The sole reason that Wall Street opposes the equality of information is so that Analysts would no longer be able to alert their large institutional clients about material information gleaned in a closed-access call or meeting, before the public has access to the same information. This current imbalance of information is antithetical to the principle of a fair marketplace and enables institutions to trade and profit on material information which is not available to the investing public. Please pass the proposed regulation and restore some fairness to the market. Best regards, Jim Healy


Author: charles hollabaugh at Internet Date: 04/27/2000 1:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe that the proposed regulation is in the best interest of the investor and should be approved. The investor not the analyst is the one who must make the choice for his investment. The more information the investor has the better HE or SHE can make that choice.


Author: "Aubre D. Howell" at Internet Date: 04/27/2000 3:47 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To Whom It May Concern. I am writing to express support for the proposal to require that publicly traded corporations fairly disclose to all interested parties any material information. Equal disclosure strengthens investor-friendly status between individuals and securities analysts/institutional managers. Tank you Aubre Howell


Author: "Humphries; Nancy " at Internet Date: 04/27/2000 4:01 PM Normal TO: RULE-COMMENTS at 03SEC Subject: FW: File No. S7-31-99 -- Regulation FD ------------------------------- Message Contents > BellSouth Corporation has carefully read and considered the Commission's > Regulation FD proposal. We are mindful of the Commission's concerns > regarding selective disclosure but respectfully disagree with the approach > enbodied in the proposed Regulation. > > Companies subject to the Regulation would be significantly adversely > impacted in their compliance efforts > > While the "materiality" of some corporate disclosures is apparent (e.g., > earnings for an upcoming period to fall 5% below consensus estimates), > most information imparted in the course of communications with analysts > does not fall within clear-cut lines of materiality. Companies > continually disclose bits of information to analysts so they can construct > their models and advise their clients as to expected company performance. > This information may be immaterial in isolation but material in > combination or within the context of the analyst's conclusions. > Furthermore, information considered immaterial by a corporate official > when disclosed may prove to be material by subsequent market reaction. > But even that indication may not be clear, as factors affecting stock > price movement are difficult to establish with certainty. As a result, > companies' compliance with Regulation FD will of necessity be tested and > validated in hindsight. > > Unlike prospectus or Form 10-K disclosures that can be carefully > considered and crafted by corporate officials, accountants, and counsel, > informal disclosures that would be subject to Regulation FD are often > impromptu and given in question and answer sessions, telephone conference > calls, one-on-one meetings and other unstructured sessions. It would be > unduly difficult, burdensome, and costly for corporate Legal Departments, > Investor Relations Departments, and Public Relations Departments to > monitor communications with all third parties sufficiently to ensure > compliance with the proposed Regulation. > > Liability to companies deemed non-compliant could be severe > > It would be very difficult for companies to defend themselves in SEC > enforcement cases where stock price movement implied material information > was "selectively" disclosed, regardless of the reasonable judgment of > company officials prior to disclosure. > > Companies that were deemed to have failed to file a required Form 8-K > presumably would lose their Form S-3 eligibility, a severe penalty > considering a potentially inadvertent mistake of judgment as to > materiality. Of more concern, companies in registration could face civil > damages or rescission claims from investors from material omissions if a > required Form 8-K was not filed. > > Under the proposed Regulation, persons outside the direct control of the > company ("agents") could impart liability to the company through their > disclosures. Significant transactions in which BellSouth has been > involved recently have been leaked to the media prior to consummation and > disclosure through normal press releases. These leaks may have come from > investment bankers or other agents of the company. Regulation FD > disclosure should not be mandated nor should liability attach to the > company from such third party disclosures. > > The public interest would not be served by Regulation FD > > The two most likely impacts of Regulation FD would be that companies > sharply curtail their communications with analysts or sharply increase > their public disclosures through press releases and Form 8-K filings. > Analysts are a critical channel for corporate information, and their > analytical and interpretive overlay add perhaps even more value to the > market than the disclosure of raw data by corporations. Curtailed > disclosure would be a disservice to the market, but this is a realistic > possible reaction to the proposed Regulation. > > Over-disclosure is the other most likely reaction. Companies concerned > that after-the-fact market reaction may indicate that material information > was selectively released may overreact by issuing press releases and > filing Form 8-K reports in such volume that the prominence of truly > material disclosures is lessened. > > Regulation FD does not create exceptions for many needed transactions > > A number of questions are presented by the proposal. How do companies in > registration resolve the duty to disclose under Regulation FD while they > are in the "quiet period"? Can issuers disclose material non-public > information to buyers of their securities in private placements without > making a general public announcement or filing? How can information be > shared with potential investors in roadshows without triggering a general > disclosure obligation? > > The presumed benefits of Regulation FD do not justify the detriments > > We do not believe that selective disclosure is either epidemic or a > growing phenomenon. We note that recent studies by organizations such as > National Investor Relations Institute indicate that more and more > companies are holding conference calls that are open to members of the > media and individual investors. Companies are now web-casting analysts > meetings over the Internet. Organizations such as NIRI are urging > companies to open their disclosure practices and they are doing so. > Chairman Levitt's campaign against selective disclosure is influencing > corporate practice. Given the anecdotal and empirical evidence that these > initiatives are effective, we do not believe that Commission regulation is > either warranted or would accelerate the evolving disclosure practices. > > For these reasons, we strongly urge the Commission not to promulgate > Regulation FD. > > Respectfully submitted, > > Nancy C. Humphries > Vice President, Investor Relations


Author: "Rahul Joshi" at Internet Date: 04/27/2000 8:40 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Hi, I am against the selective disclosure sought out by Wall Street. Rahul


Author: "Philip R. Kohls" at Internet Date: 04/27/2000 1:42 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No.S7-31-99 ------------------------------- Message Contents To: Securities and Exchange Commission: Please end this rule of partial disclosure. Company information that is meant for the public should be given to all at the same time. How to interpret that information will be determined by the brokers' skills and investor savvy. Earlier access to information has nothing to do with ability, just positioning for a head start arbitrarily denied independent investors. Yours, Philip R. Kohls, PharmD


Author: Henri Lajer at Internet Date: 04/27/2000 1:51 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation fd: file#s7-31-99" ------------------------------- Message Contents Dear Sir I would like to made my voice heard concerning this above proposed legislation. I believe that it is vital that all companies must be made to give out important information to Wall Street analysts simultaneously to the public at large. HENRI LAJER Technicolor employee. North Hollywood, CA.


Author: at Internet Date: 04/27/2000 2:05 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To: SEC RE: Proposed Regulation FD: File No. S7-31-99 To Whom it May Concern, The general investing public has every right to know the facts about any company they are investing in at the same time as Industry Analysts. To state otherwise is to take a position protecting the "insider" system that has existed in the past. Respectful submitted, Edward A. Loseman Self Employed


Author: "john mac donald" at Internet Date: 04/27/2000 4:43 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Selective disclosure is UNAMERICAN. What people do with the information is what is important. Many individuals will continue to seek advice on items they do not understand. I hope that the SEC will tear down the information wall which divides the general public from selective financial insiders. This will promote equal and simultaneous access to information for everyone. Industry professionals have a built in advantage even when information is available to everyone simulataneoulsy. These professionals are experts in their field and can act in their clients interests as they newly optained information becomes available. It is only fair that the individual investor has the right to access and interepret information as quickly as an industry professional. Please stop selective disclosure. Make information available to all who care to find it. Sincerly, John K Mac Donald Jr.


Author: Michael Mathews at Internet Date: 04/27/2000 11:48 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To Whom it May Concern: I am writing to express support for the proposal to require that publically traded corporations fairly disclose to all interested parties any material information. The United States can take pride in the fact that it has the best regarded reporting standards in the modern world. Anyone who has read a prospectus for a global or international mutual fund is familar with the disclaimer that investments in foreign securities may entail greater risk. To quote from the prospectus of the AIM Global Growth Fund: "Foreign companies generally are subject to less stringent regulations, including financial and accounting controls, than are U.S. companies. As a result, there generally is less publicly available information about foreign companies than about U.S. companies." I see no reason that the United States should permit corporations to selectively disclose material information to securities analysts or instititutional managers prior to any other investors or potential investors. In fact, I believe that equal disclosure further strengthens our investor-friendly status. My own investment portfolio includes a variety of instruments including mutual funds, individual company stocks, stocks selected by screening mechanisms, treasury bonds and cash equivalents. I have taken great pains to educate myself about financial statements and investing risks and strategies. I have read the prospectus of each mutual fund, and I have read the 10-K and 10-Q reports of the individually selected companies. I realize that we have a long way to go in educating our citizenry about the benefits and risks of investing, but we have made great strides in the past several years. Requiring complete and fair disclosure of material information is another step down the path of facilitating individual financial control and the increased prosperity of our citizens. Thank you for your consideration of this matter. /s/ Michael Mathews -- ------------------------------------------------ | Michael Mathews michaelm@sanfranmail.com | | San Francisco, CA | ------------------------------------------------


Author: "Steve McDonnold" at Internet Date: 04/27/2000 12:03 PM Normal TO: RULE-COMMENTS at 03SEC Subject: YES on Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents There is no reason why Wall Street analysts should receive preferential disclosure of information from publicly-traded companies. In fact, this age-old practice should be outlawed. Please pass Reg FD.


Author: Mark Menke at Internet Date: 04/27/2000 11:57 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Sirs, I fully support the proposed rules concerning fair disclosure. To allow a select few early access to material information is not justified. Please force companies to follow disclosure rules that would benefit the general investing publice. Thank you, -Mark Menke -------------------------- "There is an ancient Celtic axiom that says 'Good people drink good beer'. Which is true, then as now. Just look around you in any public barroom and you will quickly see. Bad people drink bad beer. Think about it." - Hunter S. Thompson


Author: Barry Minai at Internet Date: 04/27/2000 11:16 AM Normal TO: RULE-COMMENTS at 03SEC Subject: proposed Regulation FD:File No.S7-31-99 (fwd) ------------------------------- Message Contents I am stongly in favor of full disclosure rule. It is the only way for the public to have a fair and even playing field against the wall street giants. Thank you. Barry Minai


Author: Larry at Internet Date: 04/27/2000 2:51 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Public disclosure should be -- PUBLIC. This is common sense. Disclosure to analysts is not public disclosure. Analyst privileges are no different from conspiracy via a trust. True, it's cheaper and easier for many companies to use PR firms and circles of well-known analysts; disseminating and defending information in the court of public opinion is painful and difficult. But although analysts may offer a route that is cheaper and easier, it's not a FAIR route. We can't blame companies for using this route if it is encouraged by statute and policy; but there is no reason to encourage such behavior. Lawrence Morton 2816 Kensington Dr Kalamazoo, MI 49008


Author: "George Moser" at Internet Date: 04/27/2000 2:47 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Having read a number of opinions on this matter I can only conclude that the advance release of market price sensitive information to selective interests serves the cause of no one but those selective interests. There is absolutely no compelling argument in support of selective disclosure. George Moser


Author: Jeffrey Mumford at Internet Date: 04/27/2000 1:29 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I strongly support the rule (Proposed Regulation FD) requiring, among other things, that companies no longer engage in the practice of discreetly disclosing important information to Wall Street analysts without also giving that information to the public at large. Jeffrey Mumford


Author: "SHERL PERKINS" at Internet Date: 04/27/2000 1:28 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File no S7-31-99 ------------------------------- Message Contents Stop selective disclosure! Mr. Sherl W. Perkins Retired, Boeing Manager


Author: Eric Rasmussen at Internet Date: 04/27/2000 2:07 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Ladies and Gentlemen, I am writing to support the new proposed rules (Proposed Regulation FD: File No. S7-31-99) to combat selective disclosure of information by public companies. I use online brokers to invest and would like the same access to financial information that the analysts enjoy. Sincerely, -Eric Eric Rasmussen United States National Sales Manager Nikkkei Electronics Asia Nikkei Business Publications Ph# 415-902-4822 Fax# 408-327-1139 email: eric-nea@pacbell.net


Author: at Internet Date: 04/27/2000 5:04 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD; file No.S7-31-99 ------------------------------- Message Contents I believe the same information companies give to Wall Street analysts should be given to prospective investors. Without this information the investor is placed at a disadvantage,in my opinion. The analyst may give a " slanted " evaluation because of a vested interest & place undue risk on the " street investor ". Signed, Loren Roberts, Retired & Investor seeking valid information to make an intelligent evaluation of a given stock.


Author: at Internet Date: 04/27/2000 4:01 PM Normal TO: RULE-COMMENTS at 03SEC Subject: FD: File NO S7-31-99 ------------------------------- Message Contents STOP selective disclosure. It is biased and goes against everything our economy is built on. Tracey Roberts


Author: Robert Sarao at Internet Date: 04/27/2000 4:39 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- 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


Author: Dave Scott at Internet Date: 04/27/2000 12:07 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: No. S7-31-99 ------------------------------- Message Contents Help Stop Selective Disclosure, please. We all deserve a level playing field. The SEC should do more to protect the small investor. Dave Scott


Author: at Internet Date: 04/27/2000 4:41 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe individual investors should have access to the same information as brokers by mandating company information be released to the news media instead of just 'leaked' to a select few. Thank You.......................Carol Siris


Author: Lydia Sund at Internet Date: 04/27/2000 3:40 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No. S7-31-99 ------------------------------- Message Contents Please move ahead with the new regulations! Lydia Sund


Author: "Michael Tekel" at Internet Date: 04/27/2000 3:54 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD, File No. S7-31-99 ------------------------------- Message Contents I am most definitely in favor of SEC advocating a level playing field for all investors by making pertinent information available to the public, and not to analysts, brokers, the so called"high rollers" who more often than not benefit from early information. Sincerely, Michael G. Tekel


Author: "dsthomp" at Internet Date: 04/27/2000 1:04 PM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Gentlemen, Let the public in on what the brokers get before us. Many of us don't use anything except research and common sense guide us. Give us a "Fair Shake", Please! Thanks Don S. Thompson 43 845 Portola Ave. Palm Desert, Ca. 92260 760 568 9052 No affiliation with anyone.


Author: "Touzalin; Eric L; JR; CMFBP" at Internet Date: 04/27/2000 4:10 PM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sir or Madam, Please put an end to this selective disclosure policy that is currently in effect. Every investor has the right to know the facts as well as the Wall Street analysts. Thank you. Eric Touzalin


Author: craigweaver at Internet Date: 04/27/2000 1:32 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I agree that information is becoming more available with technologies, but as has always been the case, those with the most money (analysts, investment companies, etc...), get the "best" information earlier than the stockholders and the general public. This new regulation FD probably won't erase that problem, but it will let people know where right and wrong is, and let them factor in the consequences of their actions. Because they get away with it, doesn't make it right. I'm in support of Proposed Regulation FD: File No. S7-31-99. Regards, Craig Weaver Micron Technology Manufacturing Systems Boise - Assembly (208-368-4650) craigweaver@micron.com


Author: Ray Wilber at Internet Date: 04/27/2000 1:54 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No.S7-31-99 ------------------------------- Message Contents Dear Sirs: It is in the best interest of all Americans for the SEC to ban selective disclosure.To eradicate this tool of wall street and let all Americans know what is transpiring within corporations is in the true tradition of George Washington ,Thomas Jefferson and our other founding fathers.Let us as individual investers,make our own decisions on the same facts as wall street.It is our money and we have a right to know all the facts.No small band or group should hold the advantage over the rest of the population regarding financial,investment,or public company information Thank You, Ray Wilber


Author: Tom Wilson at Internet Date: 04/27/2000 3:30 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I support the proposed Regulation FD by SEC. Thomas Wilson Savant Software, Inc.


Author: Annenberg at Internet Date: 04/27/2000 10:55 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents I am a college student and I do not have the money to hire a full tiem brokerage service. In addition, I enjoy doing my own reading and my own research about companies and understanding how they are evaluated, and how all the numbers work. I do not like being fed any information without understanding where that information comes from. I agree that I might not have the same level of information and it might take me a long time to understand it all, but that's the point of learning and doing things on your own. I disagree with the SIA because I do believe I am intellegent enough to make my own decisions about the value of securitites. If I make mistakes then I learn from them. I bet you full brokerage firms have made tons of mistakes but they always cover them up. I am not ignorant nor am I emotional when it comes to the stock market. I am not foolish to gamble with my own money. Furthermore, analysts do not make the market less volatile because they do not have complete control over who buys and who sells. If a company is public than so should its records, because this just may lead to companies being able to hide more things in there numbers and not have to disclose them to their investors. In the end, it is the public's money that is buying up these shares, therefore, we have a right to know about what we are buying into. Jenny Yazedjian Student at the University of Southern California

http://www.sec.gov/rules/0427b06.htm


Modified:05/17/2000