Date: 05/14/2000 1:32 PM Subject: In reference to proposed rule S7-31-99 In reference to proposed rule S7-31-99 Dear Sir Ma'am, I would like to exercise my right to voice my comment to the upcoming proposed rule. Since the inception of the market there has always been those with current and more thorough information on companies than the private investor. The market analysis, market marker and other large institutions have privy information thus giving them the upper hand over the general public. Not only that, but they can use the past tense information available to the public to generate buy/sell recommendations, when in fact they have in their possession current information to sell/buy into the volume. What is to stop scalping, front loading, inside trading and selective disclosure to the financial world, especially select clients? If all information is not available to all, then does this not constitute by definition insider trading, with possible front loading and scalping as a result? I fully understand that anyone with a few hundred bucks can come on the Internet and be an analysis. They post their interpretations, innuendoes, and speculation without a shred of duty, best effort DD or post the truth to the best of their knowledge. These types adapt information to their own agendas regardless of whether it is emotional or intentional to gain profit. However, this is a small percent of the posters on line and most are identifiable by the hidden aliases they use, not to mention, constantly finger pointing blame for their financial situation. These types do not want you to believe the company but their interpretation and manipulation of information. Some are very articulate and know the language very well as they pose as your friend as they perform POS (Purposely Omit Syntax) and PAS (Purposely Add Syntax). The only way to combat this type of intentional manipulation of information regardless of intent is by full disclosure of all information to make a level playing field. More and more as the information age evolves with people taking the responsibility for their financial future into their own hands, it is critical that the small investor be given the same right to information as the big institutions. Most small investors in order to pay taxes have an accountant that can interpret the financial data of a company. But what about the big brokers have burned a lot of small investors. How many times have the story been told that brokers are mostly 100% wrong in their advisement? Because of that the small investor does not seek professional advisement. Small money does not attract a financial advisor worth a hoot. So even if they do, then who do they trust and establish a relationship of truth. How can an industry be so fraught with medocrity and absolute oxymoron results? This is the main reason people have gone to being their own financial advisors and most are for the first time actually making money in the market now. It has been claimed that small investors are the cause of the market volatility and I disagree. Most of the volatility in the market comes from institutions that are more skittish that any small investor. They are also privy to information the general public is not allowed to have in their possession. Presently, if the small investor does what is laid out by the SEC and other agencies to do their own DD, this causes a large phone bills and in some cases travel expenses to keep up with their investment. However if they are successful in acquiring the information through their due diligence and cost then comes the worry of whether they are breaking a rule such as front loading or inside trading. However, most of the information unknown to the small investor is already know about by the analysis and other that are privy to full disclosure. Is not selective disclose by companies and financial institutions been more harmful than benefit? The approval of the small investor to have an equal playing field is crucial to stabilizing the market. The small investor sector is growing every day. The rule needs to change to comply with the new era. If the small investor has the same information then making an investment is more likely to happen than a speculative play for a day or so. Plus it helps to combat the false information and misinterpretations to the Internet where anyone who can get on line, win a popularity contest with well written posts and friendly concepts as your friend, so they can effectively twist information to their own agenda. By allowing the small investor the same information a lot of false interpretations can be resolved at the source. Most message boards welcome the challenging of information as per the constitution. Better investing habits and less day trading can be established when the general public is on the same playing field and should provide less volatility in the market. A level playing field of information will build strength in the market. Insider trading, false interpretations of information, scalping, front loading and every other scenario the general public reads in the market will have a harder time being pulled off because the playing field will be even. False information by speculation and interpretation of information that reigns on the Internet is nothing more than a tactic coined "Adaptation of Information." This is the most harmful information available because small investors are advised not to believe the companies that are liable to the SEC but to them and their sources and what not. However, this can be combated by full disclose so the truth can be evaluated and not the opinion or interpretation of someone no one knows and probably never will. This is growing and spreading like weeds across the Internet because small investors do not have the same information as the big players in the financial world. This also helps a lot of evil forces that reign in the marketplace to take advantage of the small investor. As the market rule is to buy low and sell high the small investor already has all the guns pointed against them. Full disclosure would at least assist in the small investor knowing why they made an investment. The only way to prosper investing and curve away from day trading, false information, interpretations, opinions, and speculation is all fundamental data to be fully disclosed and available to the entire financial world and not just the analysis and large money sectors. I am not a financial advisor or anyone trained in the market aside from over three years investing on line. Gary Swancey