Date:    03/21/2000  11:28 AM

Subject: Proposed Regulation FD: G. Karpf's comments on

To Whom It May Concern:
     
First I would like to applaud the SEC for addressing and opening up for 
debate the issue of selective disclosure.  It is a loophole to the 
insider trading regulations that is long overdue for correction.
     
Despite anything the Securities Industry Association ("SIA") may have to 
say on the subject, selective disclosure ALWAYS RESULTS IN INSIDER 
TRADING.  It would be gross naivete to think otherwise.  Those privy to 
the disclosures can and do trade based on that inside information and 
materially profit from it.  As the SEC has correctly stated in its Fact 
Sheet of Dec 15, 1999,
     
"Those privy to selectively disclosed information have an unfair 
advantage over other investors, who learn of the information only if and 
when the issuer later makes full public disclosure. By that time, the 
information often has resulted in a significant change in the share 
price or higher than usual trading volume."
     
To argue the above or offer evidence in its support would be a pointless 
endeavor. The truth it contains is entirely self evident.  Selective 
disclosure is a euphemism for inside information.  It is high time to 
eliminate this unfair advantage granted the large investment houses.
     
In closing, I urge the SEC to withstand what I am sure is to be a storm 
of protest by those with vested interests in selective disclosures; 
namely, the large investment houses.  And who could blame them for 
complaining when millions of dollars worth of competetive advantage are 
stripped away.  Any arguments they may put forth against Regulation FD 
will be disengenuous at best and outright lies at worst.
     
Regulation FD should be implemented as soon as possible in its undiluted 
form as it is set forth in the SEC's Fact Sheet.
     
Respectfully Yours,
     
Glenn Karpf
Private Investor