Date: 03/25/2000 8:38 AM Subject: Regulation FD comment - File No. S7-31-99 I agree with the information below and believe that full disclosure should be encouraged. SEC'S REGULATION FD AIMS TO ELIMINATE SELECTIVE DISCLOSURE Regulation FD was proposed by the SEC in order to stamp out the pernicious problem of selective disclosure. Selective disclosure, which is illegal, can occur whenever a company shares material, market moving information with a single individual (such as a Wall Street analyst) or a small group of individuals (such as a group of analysts on a closed conference call). The problem, of course, is that the recipient of the selectively disclosed material information has an opportunity to profit from that information before the general public. Whenever a company excludes individual investors from an earnings conference call, they're risking selective disclosure liability. Regulation FD, if approved, will make it easier for the SEC to investigate and prosecute selective disclosure offenders. While the proposed ruling stops short of mandating open conference calls, the SEC makes it clear that the easiest way to comply with the regulation is to open up the call to the public. Kevin McCarthy C. H. Robinson 8100 Mitchell Road Eden Prairie, MN 55344-2054 mccakev@chrobinson.com 612-937-6731 <>