Date:    12/17/1999  12:23 PM

Subject: comments on proposed non-selective disclosure rules

Dear SEC:
     
   THANK YOU!  THANK YOU!  THANK YOU!
     
   This is something I've been waiting a LONG time for!  (Please excuse the
dangling participle -- I'm excited.)
     
   It is outrageous that some people, even if (especially if!) they're
brokerage analysts, can get exclusive access to significant inside 
information, which, of course, is exactly what it is until it's made public. 
This information should be made available to all interested parties at the 
same time.  For instance, this means that, as an increasing number of (but 
by no means all) companies are doing lately, quarterly analyst's meetings 
following earnings releases should be available by phone to all who are 
interested, "in real time" (while they're happening).  If necessary, trading 
should be halted until the news has been disseminated, so that we're all on 
a level playing field.
     
   This insider access to information has, as you're well aware, been
subject to NUMEROUS abuses over the years, often allowing the analysts' 
house mutual funds to cash out before the news gets out and the price drops. 
This is obviously unfair, and contributes to an attitude of cynicism about 
the operation of the markets.  It also puts the analysts in a serious 
conflict of interest, because if they criticize the stock too much, they may 
not be invited the next time there's inside informaiton being shared.  This, 
in turn, biases the analysis and also contributes to the general air of 
cynicism.
     
   You have my wholehearted support for this improvement!
     
   Thanks again,
     
   Andrew E. Allen
   18730 NW Astoria Dr.
   Portland, OR   97229-3200
     
   (503) 642-6751 (day)
   (503) 629-9599 (eve)