Date:    01/24/2000  9:08 AM

Subject: Proposed Rule S7-31-99
 
First, include a "link" that we can click on to send an email comment, 
rather than having to type the email address.
     
Selective disclosure hurts the individual investor every day on 
literally every security.  Witness virtually every press release that 
hits the news wire services and financial news web sites.  By the time 
the news hits the wire, the stock has already risen by three percent or 
more.
     
Every "upgrade" or "downgrade" by a major analyst is already up or down 
priced significantly by the time the actual news leaks out to the rest 
of us via the various news services which we subscribe to, whether 
Bloomberg, Reuters, Marketwatch, Briefing.com or whomever.  Some of us 
subscribe to all of them, yet we still get the news later than the 
insiders, hedge funds and other institutions.
     
The institutions and professional traders already have the advantage of 
T-1 llines and program trading software which means they can move far 
faster than the individual investor.  That part seems legitimate as 
they've made the capital investment to gain that faster speed.
     
The pre-disclosure, however, is a huge and unfair advantage.
     
If the SEC doesn't have the manpower to enforce tougher restrictions, 
then get an SEC leadership board who can effectively lobby the White 
House and Congress to get the money to implement enforcement of tougher 
rules.  This white collar "crime" is every bit as important as other 
types of crime.
     
Albert B. Frowiss, individual investor 
P.O. Box 909
Rancho Santa Fe, CA 92067
January 24, 2000