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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: Canavino Curtis-CDBI03 at Internet Date: 08/08/2000 2:30 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Commissioners, I am an individual investor who would benefit from the proposed rule change regarding disclosure and encourage you to vote for it. regards, Curtis Canavino

Author: "CHRIS COPELAND" at Internet Date: 08/09/2000 5:05 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Information to Analyst and investors ------------------------------- Message Contents I have recently heard the arguement that companies would not open up, being afraid that they would be in violation of the law change the SEC is going to vote on. That is just a red herring to the ex-parte information that analysts have profited from for years. The fact is a company that wants it's stock investors happy, will provide more information. While we may see higer price fluctuations when news comes out, both up and down, it will only be that way because the inside information is passed to the entire market at once, instead of being leaked to the privalged few. Many of these analyst must look at many more stocks than I do, thus spend less time on the stocks I have a interest in. More freedom of information will take away the second class citizen status I presently have concerning my own investments in regards to analyst. Chris Copeland

Author: "robert flagg" at Internet Date: 08/09/2000 8:47 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Regulation FD (Fair Disclosure) - File No. S7-31-99 ------------------------------- Message Contents Dear Sirs, I strongly urge that you pass the Regulation FD (Fair Disclusure) rule. After spending several years working in the Investment Banking business, I can only laugh when I hear Investment Bankers tell the public that a rule such as this would harm the investment public. The only thing Regulation FD will harm is the unfair advantage which the large Investment Banks have over the rest of us. They tend to scream the loudest only when it affects their own bottom line. Let's level the playing field. Sincerely, Robert Flagg

Author: "Fry; Jeremy" at Internet Date: 08/09/2000 3:22 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents As an individual investor who believes the best person to manage my money is me, I encourage the board to promulgate the proposed rule. Jeremy Fry Phone: 713-420-3602 Fax: 713-420-5280 ****************************************************************** This email and any files transmitted with it from El Paso Energy Corporation are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender. ******************************************************************

Author: John Godfrey at Internet Date: 08/08/2000 10:35 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Equal access to corporate informaton ------------------------------- Message Contents Knowledge is power. Wall street apparantly wishes to retain it's position as the manager of individuals investments, and will resist people having equal access to the knowledge (power) to manage their own portfolios, enabling them to trade through discount brokers, diminishing broker commissions. The argument that people may suffer from investment information overload, and therefore suffer losses, weaken the volitility checks & balances, that they should be encouraged to (coerced into) having the experts who may more properly analyse the information manage their investments; is a fallacious argument for several reasons. 1) The small minority of investors who will use the information otherwise only provided to analysts, will be the more sophisticated investors who will use the information cautiously. People who are careless with their money invest in Las Vegas, or state loteries. Investors are cautious with their money, the large majority investing in mutual funds, the adventureous through a regular broker, an donly the sophisticated, inependently. 2) Democracy is all about freedom to act independently, and knowledge is critical to freedom. With the complexities of the domestic and world economies, foreign trade issues, foreign affairs, national security, one could argue that the voter may suffer from information overload every 4 years during the elections. Is this a sufficient argument to withold information from the voter, take a paternalistic attitude, arrange to have the "experts" vote for them, or decide how they should vote? I think not. Strike a blow for freedom! John Godfrey

Author: "Brian Grindall" at Internet Date: 08/09/2000 2:06 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents As a law student who has studied the very basics of securities regulation and worked in several institutions directly participating in the equities market, I applaud the proposed Regulation Fair Disclosure for advancing the principle of full disclosure to the basic common interest - the individual investors. Although some institutions may wish to preserve the status quo, the advances in information distribution brought about by technology are not mere trends but seem to have irreparably shifted demand, power, and resources in entire industries - including those industries heavily reliant on financial information. To ignore this paradigm shift for the paternalism argued by the stalwart financial institutions would be harmful. Contrary to the contentions of the large institutions, the individual investor will hardly suffer from immediate disclosure of information. Brian Grindall Boston, Massachusetts

Author: at Internet Date: 08/09/2000 5:22 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective Disclosure ------------------------------- Message Contents As a long term investor, of over thirty years, I strongly support a change in rules that will allow all investors a level playing field. Knowledge is Power. To deny the public access to the same information is a rule that has existed far too long. As more and more individuals are taking control of their investments; with the increased use of the Internet and the possible privatization of some part of Social Security, American citizens can no longer be deprived of their right to make educated decisions. A ruling in favor of a closed group, who have a selected interest in perpetuation their advantage would be an absolute disgrace. Thank you, Judy Halpern

Author: at Internet Date: 08/09/2000 3:50 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I urge the SEC to be pro-consumer and vote "YES" on proposed Regulation FD. Investors are entitled to the same timely disclosures from companies as analysts. Often the analyst does not act in the best interests of clients, especially if the client is a relatively small investor. The individual investor needs to look after his or her's own interests and this is only possible if relevant information is made available. Why should Wall Street analysts have the advantage of knowing ahead of the individual investor what is happening to a company? Its the individual investors money that is at stake. Mary Hannon-Haley

Author: "Heltemes; Cresta" at Internet Date: 08/09/2000 3:14 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please pass Proposed Regulation FD: File No. S7-31-99. It is unfair to individual investors not to receive information at the same time as analysts. My husband and I are college educated and capable of filtering information provided by companies, it is an insult to individual investors to say we are unable of understanding the information disseminated. As more and more investors enter the market it is important for all information about a company be available. Otherwise, you will have investors making decisions on incorrect information. I believe that this regulation would make the market more attractive for individual investors. Also, the addition information would assure individual investors that Wall Street companies are not making money at their expense due to inside information. Thank you for listening to my opinion. Cresta Heltemes AOA-PAC Coordinator caheltemes@theAOA.org American Optometric Association 1505 Prince Street Suite 300 Alexandria, VA 22314 (703) 739-9200 (703) 739-9497 FAX www.aoanet.org

Author: "Bonnie Hilbert" at Internet Date: 08/09/2000 6:51 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. s7-31-99 ------------------------------- Message Contents Please rule for equal access to information at the same time. I have heard one of the SEC members voice concern about information overload. It should be obvious that all information released is gleaned by all parties for facts that particularly concern them. The level of education of the general public may be of concern on the aggregate, but many people in the U.S. have had graduate work and degrees in business, marketing, finance and economics. I think that many people in the "outback" are as well equipped to handle information as many self-styled gurus on Wall Street. Please give us the freedom to make the same solid forecasts and the same errors as those working on the Street. This means access at the same time before information is digested, filtered and released by those on the inside to the various news services. This early release affects many investment decisions that perhaps would not have been made if individuals were allowed to discern and evaluate before others voiced very subjective economic opinions. Sincerely, Jon Hilbert

Author: "robert m. hill" at Internet Date: 08/09/2000 1:43 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective Disclosure ------------------------------- Message Contents I read the Wall Street Journal article(page c1 8/9/2000) concerning this matter as it relates to Janus. I had not heard of this proposal before today but that's my fault. I want to register my support of the proposed rule. As an individual investor, I have always felt outside of the stream of inside information that flows. In this era of sophisticated information technology, I believe that all relevant information on a security should be available to all investor at the same time. I would appreciate your consideration of this view. Thanks! Robert M. Hill 11504 Mountain View Road Knoxville, TN 37922 (TN 2nd Congressional District)

Author: "Jackson; Tony" at Internet Date: 08/09/2000 1:37 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am in favor of Regulation FD (Fair Disclosure), which would, among other things, 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. Thanks, Tony Jackson

Author: "Sanjay Katabathuni" at Internet Date: 08/09/2000 9:37 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 Dear Sir/Madam, As an individual investor, I believe I should have the same rights to information as an institutional investor. Providing the information is not an end in itself to any investor. The analysis of the information provides the actual value. If I as an individual investor do not have faith in my own analysis of information about a company, I would hire the services of somebody in whom I have faith. On the other hand, I might repose more faith in my analysis than anybody else in the world. But I should have a choice. A freedom to exercise all of my available options in my best interest. America is the torchbearer of freedom; freedom of choice and freedom of action. And it is this freedom that is being curbed by selective disclosure. I believe by selective disclosure, a grave injustice is meted out to all individual investors. I would urge the SEC commissioners to vote for fair disclosure. Sincerely, Sanjay Katabathuni, Individual investor.

Author: "johnlang" at Internet Date: 08/09/2000 12:34 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Ladies and Gentlemen: I write to express my views regarding the above referenced proposed regulation. The notion that selected analysts have access to company-disseminated information of events that have a significant economic influence on the valuation of a specific corporation while existing shareholders of the same company sit quietly in the dark is absurd. Stated differently, why should I, as an owner of a corporation, be directed to an analyst to obtain information about my owned company? Is your view that it is now not the responsibility of management to advise all stakeholders of significant events that may have a material impact on the value of a corporation? Further, is it your belief that this management should direct this information to the analyst, who act upon this information, before being presented to me as an owner? I suggest this should not be the case and encourage each of the Commissioners to vote in favor of shareholders and their right to information from corporations in which they have a current or prospective interest. Further, I would prescribe significant penalties be assessed to a corporation's management for selectively informing shareholders of economically significant activities. Best regards, Dr. John Lang CPA Houston, Texas

Author: Lannings at Internet Date: 08/09/2000 12:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Get with the public FOR A CHANGE. Let us have a few of the perks you grant those greedy brokerage "houses." Let us have the new when it is most timely! Irvin Lanning ilanning@empowering.com 4 Robin Ct. Edwardsville, IL 62025

Author: "Simon" at Internet Date: 08/09/2000 10:29 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Am voting for fair disclosure for the public. Simon Loli

Author:  "Mikkelsen; Carl"  at Internet
Date:    08/09/2000  9:50 AM
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents 
Dear Sirs/Madam:
I support regulations which require uniform disclosure to brokerage-firm 
analysts and the general public.
The current system of selective disclosure impacts me as an individual 
investor in two ways:
1) For situations where I make my own investment decisions, I do not have 
the same information as the institutional traders, which lowers the 
efficiency of the market and places me as a personal disadvantage.
2) Where I seek the counsel of investment advisors, brokers, and analysts, I 
have no independent way to verify that the "whispers" and secret disclosures 
so many brokers use to tout stocks are real, and not simply sales 
The market works, only works, because all buyers and sells have the same 
information. Companies, including my company, go to great lengths to control 
the flow of information so that no employees are either trading on inside 
information, or inducing others to do so. Providing a special loop-hole 
where certain privileged investors have information denied to others is not 
in keeping with market efficiency, or equal status of all investors.
Thank you,
Carl Mikkelsen
Splash Technology, Inc.

Author: Harihara Moorthy at Internet Date: 08/09/2000 9:46 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I wholeheartedly support the rule-change to prevent companies from releasing critical market-moving information exclusively to select wall street analysts. Thanks, H. Moorthy ===== .._ /(_) _ | | | Harihara Moorthy | |__|_(510)440-1610(h) \__/ (510)771-3592(w)

Author: "Diane Peters" at Internet Date: 08/09/2000 5:42 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am in favor of the proposed rule. While there are investors who will not be able to use the information effectively, its availability will be no more damaging than anything else that can be misunderstood and promote a mob mentality. For those who are willing and able to learn to use the information, it will be extremely valuable. We will be able to make intelligent decisions on how to invest our own money in order to achieve our goals, and this increase in wealth can only be good for the American economy. Diane L. Peters

Author: val scott at Internet Date: 08/09/2000 9:53 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear SEC, I am strongly in favor of changing the rule about disclosure of information from the curent "selective" to "full", in order that ALL of us who trade, no matter how "small", may be operating from the same knowledge. Such would be the democratic way. Thank you, Valorie Scott, Westfield, MA

Author: "Richard K. (Rick) Sykes" at Internet Date: 08/09/2000 6:45 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Regulation FD ------------------------------- Message Contents Folks, The only way to have a fair stock market is for every investor to have access to the same information and at the same time. Allowing companies to disclose business information to a select group of investors gives those investors an advantage in the market until the information becomes widely known. Those investors who wish to have business announcements interpreted for them by stock analysts would still be able to do so. Please vote for Regulation FD. -- **** PLEASE DO NOT SEND ME ATTACHMENTS > 50 KBytes **** **** WITHOUT PRIOR ARRANGEMENT **** Rick Sykes Senior Engineer, SysAdmin LinCom Corporation rsykes@lincom-asg.com

Author: RafaelGV at Internet Date: 08/09/2000 11:17 AM Normal TO: RULE-COMMENTS at 03SEC CC: fool@fool.com at Internet Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents It is amazing how paternalistic the goverment can be when it suits its ends and special interest. The public can be responsible enough to pay their taxes, but not responsible enough to manage their money. Money investing information is "overload", but billions of paid advertisement bits a day is good business, not information overload. How odd! As a private investor who have made all my investment decisions and been beating my ex-broker by double, I think the SEC should be on the side of the public that wants the same courtesies extended to the big players. If the SEC wants to decrease "information overload", limit the amount of advertisement we are all subjected when we are trying to watch our favorite show, or the amount of red tape needed to deal with the most simple of goverment transactions. Giving the public information that may benefit their purse, instead of taking from it, is what the SEC should do, not the other way around. Approve the FD! Rafael Gonzalez-Vizoso, MD

Author: at Internet Date: 08/09/2000 2:20 PM Normal TO: RULE-COMMENTS at 03SEC CC: JVaughan@levi.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. The rules have changed in case somebody hasn't noticed. The same old-same old good ole boy network just doesn't cut it anymore. In a day and age where consumers and investors are extremely interested, knowledgeable, and educated, the same tired rules where favored analysts get advanced information is unfair, unethical and quite frankly, wrong!!! This is the type of action that just has to stop. And stop right here and now. Why make it easy for analysts? You know why various companies want favored analysts specially treated......and that is why it should end. Fair and timely disclosure for one and all! The consumer and citizen is alive and well. And the old ways are dead, obsolete and by-the-wayside. Why continue under the wrongful pressures of the analysts' lobbyists? Take a stand and do the right thing. Patrick R. Wilson President Hanley-Wilson & Associates Knoxville, TN 37938 865/922-3380

Author: "Young; Dan" at Internet Date: 08/09/2000 3:49 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. 57-31-99 ------------------------------- Message Contents Ref: Proposed Regulation FD: File No. 57-31-99 Dear Commissioners: I strongly and respectfully urge you to support the small investors of our nation in their efforts to obtain corporate information at the same time that it is received by large investment houses. I am perfectly capable of managing my own money and do not need an analysis to interpret information for me, particularly when that information is made available to the investment house and its large customers before it is available to me, and other small investors like me. Please do the right and fair thing and vote for the implementation of the rule. Thanks for your considerations. Very truly yours, Daniel R. Young, C.E.O. Federal Data Corporation