Date:    02/02/2000  8:16 PM

Subject: File No. S7-31-99

Dear Sirs,
     
Thank you for providing a forum for investors to provide their opinions 
regarding selective disclosure.  I've been an independent investor for 
roughly 35 years and I'm very pleased with the recent trend companies have 
taken to improve disclosure.  I was interviewed by Bloomberg on this subject
last fall and staunchly support those providing web access to conference calls.
     
The Principle:
I agree totally that rules and laws need to be clarified and modified so as 
to totally block any legal method for a company to selectively disclose 
information.  I have lost hundreds of thousands of dollars as a result of 
people trading on their access to information that is not available to me or 
the general public.  The term "selective disclosure" is simply nice phrase 
describing a legal loophole that allows selected people to legally trade on 
inside information.  At the end of the day, there are only two kinds of 
information: Public and Inside.  Selective disclosure fits in the later 
category.  By law, you can't trade on inside information.  If the current 
practices don't violate the letter of the current laws, they certainly 
violate the intent.
     
Specific Issues:
There will be those who say your proposal in Rule 101(c) describing "person 
acting on behalf of issuer" is too vague and could cause undue burden.  I 
propose this be changed to officers who have access to information not 
released to the public.  ("Released to the public" will need to be tightly 
defined)  An officer of a public company needs to be responsible and 
cognizant of their responsibilities.
     
In Rule 100(b) you should clearly state that any information transmitted in 
an effort to secure commercial credit be marked as insider information and 
that if any trades are made as a result of the financial institutions 
release or breach of confidence of this information that all fines and 
prison sentences be automatically doubled and that there be a minimum prison 
sentence with no possibility of parole.
     
Your proposed rule states that information must be released simultaneous to 
it's selected availability.  I feel this should be changed to before the 
start of a release.  I would also propose that it be published not sent to 
or available to be published, but actually published, in a publicly 
available place.  A company web site, another commercial site or a 
government site, among other non Internet methods, would fit the definition. 
I would also propose that the company be required to email any and all PR or 
other information releases, at the time of their original release, to any 
party that requests such service.  This is a zero burden and cost exercise 
for the company.  If additional facts are brought out during a disclosure 
that are not included in the original release, I propose the company be 
allowed one hour to publish those facts as an addendum to the original post. 
These rules would not disadvantage those attending the meeting since they 
could pick up a copy at the same moment it is published and they have full 
access to communicate during the meeting.
     
Again, thank you for your support.
     
Sincerely,
     
Paul McWilliams
President
MTS, Inc.