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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: Dawn Badgley at Internet Date: 08/09/2000 7:59 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Full disclosure ------------------------------- Message Contents I believe that Full Disclosure can work for all of us. Those investors who enjoy researching and analyzing market data can benefit and make substantially sound decisions with information gathered through full disclosure. I don't believe it will put anyone out of business because people will still listen to the analysts. Those who suffer from overload will only listen to the analysts or continue to trust to fortune. We are all subject to overload at some point and regarding some subjects. How is that different from any other topic of available information and why should this be any different? Each of us absorbs what we can and for those who can't, we are dependent on the professionals. Myself, I like accessing both. Thank you for reading my opinion. Dawn Badgley

Author: Martin Bennett at Internet Date: 08/09/2000 6:36 AM Normal TO: RULE-COMMENTS at 03SEC CC: bdawson@qualcomm.com at Internet Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents The fear that Wall Street Analysts losing the ability to manage 'us' the 'little-people' is amazing. I'm one of the many people who have a better understanding of the technical market than most Analysts. I don't need them telling me what to invest in and limiting when I can receive information. Martin Bennett Business Process Analyst Qualcomm, Inc. W) (858) 658-2564 P) (858) 635-0261

Author: at Internet Date: 08/09/2000 7:30 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Reg FD: File No. S7-31-99 ------------------------------- Message Contents Strongly support change which would make information available to individual investors at same time as analysts. Willard M. Burleson

Author: "Cahill; Tim" at Internet Date: 08/09/2000 11:46 AM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Mr. Katz, I am writing to express my approval of the proposed regulation "Regulation FD: File No. S7-31-99." As the markets open up to more individual investors, thanks to the explosion of on-line trading and self-service brokerage accounts, it is more important than ever that information be allowed to flow freely and quickly among market participants, to include individual investors. As an individual investor, I have the majority of my retirement funds allocated to individual stocks in my portfolio. In order to make the wisest decision possible, it's vital that I have access to the same information at the same time as the major brokerage firms' analysts do. Coupled with my own research (thanks to the Edgar On-line system), earnings estimates and other information, currently disclosed selectively by some companies, help me make the best possible investing decision at that time. Contrary to the SIA's belief that I am unable to make my own investing decisions, I believe I have made some very wise decisions to date. However, I also only invest in companies that currently do not participate in selective disclosure. If your regulation is passed as proposed, I will have a broader range of companies from which to choose, and for that I will be grateful. In the end, I believe the analysts will also profit. At present, I do not pay much attention to analyst's ratings because many of them are only rating the companies for whom they also make a market. This, in my opinion, presents a large bias in favor of a "buy" or "strong buy" rating. If the proposed regulation passes and the analysts are forced to add some extra value to their research, I believe many people will start to pay more attention to their analysis. The analysts who are first-to-market with value-added research will be the clear winner, along with the investing public at large. Thank you for accepting my comments, and I trust you will make the right decision. Sincerely, Tim Cahill 5 Adams Ave. Merrimack, NH 03054 Tim Cahill Sr. H&W Analyst FESCo - Fidelity Investments 603-791-8770


Author: "Davis; Brian" at Internet Date: 08/09/2000 8:50 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective Disclosure ------------------------------- Message Contents Dear sir, If even one of the four panelists vote against ending selective disclosure, it will be a sad day for our country. Such a vote would call into question the panelist's integrity. This decision will show who is more important and who the SEC is out to protect, the American people or powerful Wall Street analysts. I can only hope that they will hear the voice of the people of the United States, and will vote with their hearts. Thank you for your time, Brian T. Davis

Author: "Freeland; Bruce" at Internet Date: 08/09/2000 10:38 AM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents I am in full support of disclosure to all investors, not just "The Wall Street Elite" Thank You Bruce Freeland freeland.bruce@mayo.edu

Author: Dave Harnett at Internet Date: 08/09/2000 7:31 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Please vote FOR the full disclosure rule ------------------------------- Message Contents The USA is built on freedom of information not surpression of information. The argument that the individual investor is not "capable" to digest timely financial information goes against the grain of what the USA stand for. Thank you for listening DAVID J HARNETT 1605 COLUMBIA AVE. PROT ROYAL SC 29935 E-MAIL harnett@gosiggy.com

Author: "Kevin Kay" at Internet Date: 08/09/2000 9:43 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents This rule has been needed for some time. After being employed by a public company (ANTEC), I've now had the chance to follow the stock for several years. It is now fairly easy to predict when major announcments are coming. All too often, the stock price will make a radical change one day, and an announcement will appear publicly the next. This is obviously NOT fair dissemination of information to all shareholders. Pleae vote yes on this rule. Sincerely, Kevin Kay W. Kevin Kay ("Kevin") Senior Staff Engineer Electronic System Products 11450 Technology Circle Duluth, Georgia 30097 e-mail: Kevin.Kay@antec.com Phone: 678-473-2100 Direct: 678-473-8624 FAX: 678-473-8797

Author: "Richard A. Kendrick" at Internet Date: 08/09/2000 9:44 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sirs: The healthiest market would be one with the greatest amount of transparency. Keeping this in mind, I urge you to approve the proposed regulation on the subject line of this message. Too often I have seen the price of one of my securities drop precipitously on no news, and then read several days later of fundamental problems with that company. Clearly, large institutional investors had this information before it was made public. This is unethical, and can only create suspicions about corrupt practices playing a part in America's economy. Please take the correct action in this matter. Thank you. Richard Kendrick McCombs School of Business The University of Texas at Austin

Author: at Internet Date: 08/09/2000 11:45 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Re: Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Hi. I'm sorry I left my name out. It is Michael Leviton. Subject: Proposed Regulation FD: File No. S7-31-99 Author: at Internet Date: 08/08/2000 3:25 PM The unprecedented response generated from the public (individual investors) shows how important we feel this rule is. It is truly surprising. What is not surprising to me is Wall Street's reaction. They try to introduce fear into the debate. I noticed one comment by John Adams (of Adams, Harkness and Hill): "Millions of new equity investors will, as a group, underperform the results achieved by professional managers." Considering that the great majority of money managers (over 80%) manage to trail the market themselves over long periods of time, his concern for individual investors is not genuine. Mr. Adams goes on to say that it is likely that for individuals, "self-management is hazardous to their wealth." Mr. Adams really means that self-management is hazardous to his own wealth. His career and the careers of others are threatened by those who wish to take command of their own finances and futures. Mr. Adams and his ilk are not being honest about their fees, their underperformance, and now their real reasons for keeping the current system of selective disclosure in place. The SEC now has an opportunity for our nation to take the world lead in making the People more informed, more intelligent, and more knowledgable about their affairs. It is an opportunity that should not be missed.

Author: "Miller; Andra M" at Internet Date: 08/09/2000 10:07 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear SEC: Please vote to pass the proposed rule requiring companies to make information available to the public at large when they supply such information to Wall St. analysts. As an investor, I do not need protection from the information they use in making their investments when I make mine. I should think some court would find such information channeling to be unfair -- if not even unconstitutional. It seems prejudicial to me. -- Andra M. Miller - Apt. 4B 146 West 16th St. New York NY 10011-6263 ***************************************************************************** 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: Paul Milligan at Internet Date: 08/09/2000 10:18 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Yes !!!! Vote Yes !!!! The nonsense about 'people can't manage their own money', and 'people can't handle the information' is purest crap ! Paul Milligan 2212 Wininger Dr. Raleigh NC 27603

Author: "Eric Morton ((914) 435-4850)" at Internet Date: 08/09/2000 8:14 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I support the proposed regulation Eric Morton

Author: "Michael J. Nagro" at Internet Date: 08/09/2000 6:53 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Dear SEC Members, My wife, Kathryn McPherson and I are both vehemently opposed to any limitations being proposed on the release of corporate financial information to the public. As active and informed investors, we believe we should be able to access the same information as Wall Street analysts. The Internet, our most crucial tool as investors, democratizes information. Rather than further an exciting opportunity for small investor, this proposed regulation reduces our power to manage our financial future effectively. We do not suffer from any "information overload" regarding our investments. Indeed, access to charts, reports, and other forms of data only enhance our ability to make choices. Please do not strip us of that. Regards, Michael J. Nagro

Author: "Andrew O'Reilly" at Internet Date: 08/09/2000 4:57 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Hi, It would seem to me that the current rules on disclosure give a closed group of Wall Street companies what effectively amounts to inside information. With the internet now affording every investor with use of a computer instant access to information on every publicly traded company its time to change the disclosure rules and open up the information flow to everybody. I've heard arguments against changing the selective disclosure system based on the premise that individual investors will suffer from information overload. I find this argument to be completely without merit. The same computer and internet technology that provides instanteous access is also providing the tools and knowledge for individuals to process this data in highly efficient ways not possible before. I hope that you all take this opportunity and level the playing field that is so unjustly tilted against individual investing people right now. Andrew O'Reilly

Author: "Trevor R.P. Price; MD" at Internet Date: 08/09/2000 6:54 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents I am very strongly in favor of new regulation(s) that will prohibit selective disclosure! I urge establishment of such. Thank you for your consideration. Trevor Price, MD 930 Morris Avenue Bryn Mawr, Pa., 19010

Author: Greg Rambat at Internet Date: 08/09/2000 8:36 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD File no. S7-31-99 ------------------------------- Message Contents I am writing to voice my opinion of the above proposal. As a fully functional and breathing adult, I feel I am capable of making the appropriate investment decisions. In the past I have done what research I could, but, feel having access to all information readily available to all at the same time will only make me more successful. We are not talking about proprietary information. As investors, we are owners of the companies and should not be excluded or delayed from receiving any information that assists us i making those decisions. Selective Disclosure must end now. Greg Rambat Lansing, MI

Author: "Ray; Gregory" at Internet Date: 08/09/2000 9:27 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Sir, Please support Regulation FD and require that officails of public companies make all information available to the public at the same time as information is shared with the investment professionals. Please remember that these "professionals" are investing "our money". We should have the right to know what they know as it becomes available...not later. I have been a private investor for nearly 20 years. My education includes a BS in Mechanical Engineering and an MS in Chemical Engineering. I am not a "Wall Street" professional but have followed my personal investments very closely for years. During my early years of investing (1985-1991), I worked with a Stock Broker from Dean Witter and followed his investment advice very closely. He encouraged me to invest on margin. I watched and followed his advice as the value of my investments plunged from $88,000 to $4,000. I was very naive about stockbrokers and their objectives. I thought that his goal was to make money for me. I was obviously wrong as his commissions grew while my net worth dropped. During the last three years, I have learned to spend time managing my investments more closely and more safely as my net worth has climbed to nearly $900,000. I don't have a broker and depend exclusively on information that is publicly available. Please support Regulation FD. Gregory A. Ray I

Author: "Schuyler H. Richardson" at Internet Date: 08/09/2000 9:47 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. ------------------------------- Message Contents This is to register my strong support for the proposed Fair Disclosure regulation to be voted on today by the Commission. Please contact me if you need further information to process this comment. Schuyler H. Richardson 116 So. Jefferson St. Huntsville, AL 35801 256-533-1421 shr@bellrich.com

Author: at Internet Date: 08/09/2000 10:33 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Re: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents From: Tomas Saez 84 pinewood Road Hartsdale, NY 10530 Dear Madame/Sir, As we have enter a new era of communications, clarity, should be the goal of providing information. Companies "need" stop to favor a few and share with the general public their information on an equal basis. Obviously, the distribution of privileged information (it would be difficult to stop it), as mostly occur today, with by invitation dinners at posh Scottsdale, New York or Vail restaurants, or four hour rounds of golf in Maui, in which a few would continue to exchange privilege information. As for the masses, just to be a little near would be a step forward. Good luck, it is needed it. Tomas

Author: Marlene Satter at Internet Date: 08/09/2000 10:43 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please require that information be disseminated fairly to everyone, not just analysts. Individual stockholders have a right to information to make informed decisions, and they should not have to wait in line for that information if they are not wealthy stockholders being fed information by analysts at brokerage houses. Individual investors who manage their own portolios and do not have analysts at their beck and call are far more likely to be negatively affected by information released only to analysts (and then to wealthy investors). They will have to wait to see the price move on their stocks before they can act, because they will not be privy to information that the wealthy get as a matter of course. This will lower the amount of money they can make in the market and increase the possible losses they will incur. It is very unfair for the wealthy to get their information first. I am a stockholder and am far from wealthy. But I feel that I should have the right to know pertinent facts about the companies whose stock I own, or whose stock I am considering buying, at the same time as those who have a lot more money than I do. I make my own decisions concerning what goes into my portfolio, and I do not rely on analysts' opinions. But I would make better-informed decisions if I were privy to the information they receive as a matter of course. Please vote on the side of democracy and fairness. Pass this regulation to require full disclosure and end selective disclosure. Thank you. Marlene Y. Satter

Author: Patrick Serpas at Internet Date: 08/09/2000 5:37 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sir or Madam: Please vote Thursday to pass Regulation FD to prohibit companies from passing material market-moving information on to favored Wall Street analysts without simultaneously making the information available to the public at large. Thank you, Patrick Serpas 1340 E. Clower St. Bartow, FL 33830-7237 863-533-2812

Author: Brian C Sisk at Internet Date: 08/09/2000 8:52 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. 57-31-99 ------------------------------- Message Contents To whom it may concern, Believe it or not, a lot of us individual investors, particularly the ones that would be interested in timely company disclosures, are very capable of managing our own finances. Not all of us are a bunch of idiotic day-traders who buy and sell on a whim. In fact, it is the day traders who likely don't have time to use this information if they are trading constantly. Some in Wall Street have contended that we might be 'confused' by 'information overload' if we have more disclosure. This is ludicrous. Count the letters and emails you have gotten from individual investors who are fearful of all this information. Those who can't handle it won't seek it. Finally, and most sickeningly, Wall Street has contended that we can't be trusted with our own money, as we are sure to lose it. First, it's my money and I have the right to do whatever I like with it. Second, if anyone is likely to lose money, it is the 90% of mutual fund managers that regularly underperform the market. And they say that we're not to be trusted! I can beat their returns with an index fund. Please vote for the pending rule. The only thing that we have to fear is lower commissions, higher returns, and financial freedom. The only thing that Wall Street types have to fear is their jobs. Maybe that's why they've been so vociferous on this debate. Brian Sisk Western Kentucky University

Author: Paul Swaekauski at Internet Date: 08/09/2000 8:13 AM Normal TO: RULE-COMMENTS at 03SEC Subject: proposed Regulation FD (Fair Disclosure) ------------------------------- Message Contents Sirs, I am a small investor and part of a stock club and communication group which follows the market and are internet saavy. Please consider that we are fully in support of this rule which will allow information to be provided publicly at the same time that Wall Street Analysts obtain company information. Having access to this information at the time of disclosure levels the playing field for all investors, providing all the same opportunities. This is the hallmark of a free-market system. thank you, Paul Swaekauski Paul Swaekauski Operations Program Director for Globalstar Plus Programs

Author: Sumeet Valrani at Internet Date: 08/09/2000 6:41 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Re: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents My name is Sumeet Valrani > Subject: Proposed Regulation FD: File No. S7-31-99 > Author: Sumeet Valrani at Internet > Date: 08/08/2000 8:31 PM > > Proposed Regulation FD: File No. S7-31-99 > > vote yes > > >

Author: at Internet Date: 08/09/2000 8:52 AM Normal TO: RULE-COMMENTS at 03SEC CC: RMcConkey@BDBC.com at Internet CC: BSales@rsac.com at Internet CC: MVaughan@DeRoyal.com at Internet CC: VGH579@cs.com at Internet CC: HanWilPR@aol.com at Internet CC: MaxRamsey555@cs.com at Internet CC: Rankin@USIT.net at Internet CC: Michelle.Dove@JAKing.com at Internet CC: AKorte@usit.net at Internet CC: KellyPowers712@cs.com at Internet CC: RheaDan@msn.com at Internet CC: RonnieS@Cone.com at Internet Subject: "Proposed Regulation FD: file No. S7-31-99" ------------------------------- Message Contents To: The Securities and Exchange Commission I am asking that you change the rules and that companies be prohibited from passing market information through favored Wall Street analysts. It is only fair that the public be given equal and timely access. To much is added or taken away from what is released and to many opinions are added that are not what the company released when released through analysts. There are to many self serving conflicts of interest for the analysts, brokers and advisors to pass on unbiased, fair and complete information to buyers and sellers. I can't imagine that there is even a debatable issue here. What you have to do should not be based on who and how many people and how much money is spent on lobbying for or against the rules but rather what is ethically fair and morally right. If the truth could be known there have been billions of dollars lost by the individual investors who to trusted the information that their trusted broker or financial advisor sold them, earning a commission, only to ultimately find out that they did not have a chance to make any gains from the transaction either because the broker or advisor did not know any better or because he or she was blinded by commissions or required by the corporate order of his employer to meet certain objectives even at the expense of the individual. I know this to be factually correct. I have been there and have experienced it. It is as wrong as robbing a bank and I think worse. Robbery is a straight forward action whereas this is a hidden, enhanced, covered up, misrepresented and advertised action of theft. Please do your job. Require companies to disclose information to the public at the same time that Wall Street gets the information. Individuals will still have the choice to listen or not and still use the analyst interpretation if they choose. As least give us a choice. Jim Vaughan 7805 Ember Crest Tr. Knoxville, TN. 37938 865-922-3017H 865-549-5724 B

Author: at Internet Date: 08/09/2000 7:06 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective disclosure ------------------------------- Message Contents Subject: Proposed Regulation FD: File No. S7-31-99 Selective disclosure is just plain wrong. If there is any valid reasons for this, I cannot see it and have not heard of it. Jon R Wagner Pensacola, FL

Author: "Woll; Jeff" at Internet Date: 08/09/2000 10:22 AM 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 corporate information as companies provide to stock analysts--and at the same time. I recommend voting in favor of this regulation. Regards, Jeff Woll Private investor