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U.S. Securities and Exchange Commission

Comments on Proposed Rule:
Selective Disclosure and Insider Trading

Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99


Author: at Internet Date: 04/28/2000 4:57 PM Normal TO: RULE-COMMENTS at 03SEC Subject: RULE COMMENTS ------------------------------- Message Contents proposed reg. no. 57-31-99 i am against analysts getting info before the rest of us. riki andreoli


Author: at Internet Date: 04/28/2000 12:13 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Propsed Regulation FD:File No.57-31-99 ------------------------------- Message Contents Please vote for the individual citizen and consumer. Do not pass this legislation! This is not a vote for your constituents, its a vote for an industry that preys on uninformed consumers. Humberto Avila


Author: "Dale Beardsley" at Internet Date: 04/28/2000 9:17 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective disclosure ------------------------------- Message Contents I support regulation FD. D. Pearson Beardsley 432 Lime Kiln Road Lexington, VA 24450 (540)464-3107


Author: "earl bland" at Internet Date: 04/28/2000 6:36 PM Normal TO: RULE-COMMENTS at 03SEC Subject: limited disclosure rule ------------------------------- Message Contents Please stop this unfair withholding of vital information from the public at large and stock owners in particular. This practice only encourages and facilitates those with special connections to make buy and sell decisions based upon priviliged knowledge. The only way this can be honestly viewed is to recognize that it is an illegal use of inside information by selected persons acting as extensions of corporate officers for the profit of insider surrogates. It should be eliminated and banned as if it were surreptitiously performed by friends, relatives or other associates of corporate insiders. Thank you for your interest in my opinion. Earl G. Bland President Micro Works, Inc. 14175 Clarksville Pike Highland, MD 20777 301-854-0540


Author: "Lee R. Bradford" at Internet Date: 04/28/2000 8:31 AM Normal TO: RULE-COMMENTS at 03SEC Subject: I support public disclosure of corporate financial informati ------------------------------- Message Contents I support public disclosure of all corporate financial information and urge you to pass rules prohibiting companies from selectively releasing information to favored analysts. Thanks, Lee R. Bradford ___________________________ Raymond James Financial Services 309 E. Mountain Ave., Ste. 200 Fort Collins, CO 80524 970.224.2193 888.869.0400 Fax: 970.224.2194 mailto:lbradford@rjfs.com


Author: at Internet Date: 04/28/2000 6:15 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective disclosure ------------------------------- Message Contents Level the playing field and require that individual investors have access to information just like the street. thank you, Henrietta Brown


Author: "Kimberly Burger" at Internet Date: 04/28/2000 7:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: ------------------------------- Message Contents Gentleman and Ladies: I am a small investor in stocks and mutual funds. It has come to my attention that select financial professionals are privy to information before individual investors and others. One of the devices through which this is done is conference calls and even, I am told, preferred access to financial statements. These practices should be prohibited. It skews the market and gives select people and entities an unfair advantage. /s/ Chris Capozzi


Author: "Marilyn Chattin" at Internet Date: 04/28/2000 1:10 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-33-99 ------------------------------- Message Contents I support your proposed regulations concerning making full disclosure. I am opposed to the current system of selective disclosure. As an individual investor, I believe I should have the same right to information as private brokerages. Thank you for correcting this unjust system. Marilyn Chattin Touchstone Pottery 2418 Old County Road W. Halifax, Vermont 05358 touchstn@sover.net


Author: Mark Coker at Internet Date: 04/28/2000 2:03 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Regulation FD Comments from Mark Coker, Founder, BestCalls.c ------------------------------- Message Contents On behalf of BestCalls.com and our 65,000 registered members, I applaud Chairman Arthur Levitt and the dozens of other individuals at the S.E.C. who have taken bold action to stamp out the insidious practice of selective disclosure. I support Regulation FD. Regulation FD will provide the S.E.C. the authority it needs to investigate and prosecute selective disclosure offenders. The mere threat of S.E.C. scrutiny will cause every public company to adopt fair disclosure practices. Regulation FD is necessary to maintain confidence in our public markets. It establishes a framework for best practices by providing companies clear guidelines on how to manage fair disclosure. Opponents to Regulation FD have raised two primary concerns, neither of which I agree with, and both of which I will address here. 1. Opponents to Regulation FD claim it will have a "chilling effect" by reducing the quality and quantity of information disclosure. BestCalls.com response: In March of 1999, we launched a public directory of earnings conference call schedules. At the time, nearly 80% of public companies had a policy of excluding individual investors from their calls. Today, nearly 70% of public companies provide individual investor access to their calls. While this reversal in shareholder communications practices is dramatic, it didn't happen overnight. Most of these companies were initially reluctant to change their shareholder communications practices. This was not a surprise, considering that investor relations is, by necessity, a conservative and risk averse profession. In fact, a primary reason many companies opened their conference calls for the first time was to reduce their risk of selective disclosure liability. Yet after opening their calls, many of these companies learned that broader disclosure of information could actually help them retake control of their shareholder communications message. After years of feeling like they were held hostage by the opinions of a few Wall Street insiders, companies welcomed the opportunity to reach out and communicate with a broader investor audience. Many companies who were initially reluctant to open their conference calls have since increased their level of communications via webcast conference calls, management interviews, shareholder meetings and investor conferences. And contrary to the arguments of Regulation FD opponents (or opponents of the open conference call movement for that matter), the quality of the communications has not suffered. Many enlightened public companies now view disclosure as a shareholder communications opportunity and not as a burden. As companies embrace the principals behind fair disclosure, the frequency and quality of shareholder communications increases. By communicating more openly with their investors, companies cultivate shareholder trust and confidence, reduce surprises, and do a better job of attracting and retaining long term investors. 2. Opponents to Regulation FD claim that the regulation is no longer needed now that companies are voluntarily opening up their conference calls. BestCalls.com response: While many companies have indeed opened their calls to the public, Regulation FD is still required to protect the confidence and integrity of our markets. When it comes to selective disclosure, conference calls are only the tip of the iceberg. Although the open conference call movement has helped shine a bright light on the problem of selective disclosure, selective disclosure remains an endemic practice. Selective disclosure remains pervasive at private analyst conferences, one-on-one meetings, phone briefings, and invitation-only management presentations. I strongly encourage the S.E.C. to adopt Regulation FD. Selective disclosure must stop now. All investors deserve equal access to market moving information. It shouldn't matter if a investor owns one share or one million shares. Every investor is an owner and deserves fair disclosure. Sincerely, Mark Coker Founder and President BestCalls.com mark@bestcalls.com http://www.bestcalls.com


Author: "wmc" at Internet Date: 04/29/2000 4:36 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Need Good Info to Make Informed Decisions ------------------------------- Message Contents I'm keeping this short and brief.. Although I know your department has heard much on this from many individual investors I feel it is important to express my view.... As a current long term individual investor you must know it is extremely important for me to recieve as much accurate and timely information as possible. Serious individual investors are very capable of tolerating risk, given the necessary information to make good descisons. Witholding timely information from the individual investor is not fair. I will not be as inclinded to digest information delievered by a 3rd pary source, broker or who ever, as i would straight from the horses mouth. Sincerely, Greg Crysler


Author: "Michael E. Dexter Sr." at Internet Date: 04/28/2000 10:47 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Level Playing Field ------------------------------- Message Contents To Whom It May Concern, If a company is a PUBLICLY traded company, that would mean shares of said company are available to the PUBLIC. Therefore, any information about the PUBLICLY traded company, should be made available, to the PUBLIC, at the same time the information is made available to anybody else, reguardless of their occupation. Respectfully, Michael E. Dexter Sr


Author: elaine drage at Internet Date: 04/28/2000 3:38 PM Normal TO: RULE-COMMENTS at 03SEC Subject: disclosure rules ------------------------------- Message Contents A little knowledge is a dangerous thing. Please give us full disclosure rules. sincerely, david j. drage Elaine Drage


Author: "JIM ELLIOTT" at Internet Date: 04/28/2000 11:32 AM Normal TO: RULE-COMMENTS at 03SEC Subject: open information ------------------------------- Message Contents Dear Sirs: I respectfully ask the SEC to allow the individual investor to receive the same information at the same time as the analyst. I need this information to make rational investment decisions. Sincerely Jim Elliott


Author: "TERRY Flakus" at Internet Date: 04/28/2000 10:24 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed REg FD:No 57-31-99 ------------------------------- Message Contents Let's have a level field for a change. The future of the stock market is the individual investor. We need information that we can rely on. Businesses should tell us the truth and all of the truth!We own these companies! Why should they, our employees, be allowed to lie and conceal information. Do what is right! Terry Flakus, Investor


Author: djhunt at Internet Date: 04/28/2000 9:39 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. 27-31-99 ------------------------------- Message Contents I am in favor of an end to selective disclosure. Desiree Hunt Floyd


Author: at Internet Date: 04/28/2000 3:40 PM Normal TO: RULE-COMMENTS at 03SEC Subject: S7 Full & Open disclosure ------------------------------- Message Contents To promote trade and commerce fairly and equitably, full and open disclosure is welcomed. Good job SEC. A M Fonda


Author: Robert G Freiburger at Internet Date: 04/28/2000 10:41 AM Normal TO: RULE-COMMENTS at 03SEC Subject: ------------------------------- Message Contents RE: Proposed Regulation FD: File No.S7-31-99 It is my understanding that there is some conflict over this proposal. I don't see that there should be any problem or hesitation putting this in force. Any information made available to any portion of the investing public should be made available to all members of the investing public. Period. End of Story. There should be no favorites. As an indivdual investor with a long term orientation, and as a volunteer with the National Association of Investors Corporation, better known as the NAIC, I think that we the investing public, should have a fair and even chance. Robert G Freiburger PO Box 204 New London, WI 54961 freirob@athenet.net


Author: "Kent Gregory" at Internet Date: 04/28/2000 11:21 AM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD" ------------------------------- Message Contents Sirs; It seems to me that this is a timely and important move. It has long seemed unfair to me, as a small private investor, that large money managers are privy to information that I am not able to acquire. It smacks of Insider Trading to the small investor, such as myself. Why should the weight of one's investment portfolio entitle one to information that is not yet Public Domain? Doesn't this seem to, at least, infringe upon the rules concerning Insider Trading? Over the years we have been witness to a number of prosecutions related to the disbursement of Inside Information to private investors, and the profits yielded therefrom. It seems little different to me that a Professional Investor acquire this information for a select few with the funds large enough to invest at the minimum level required by many of the Funds that are gaining value through this type of information gathering. I may be ill informed concerning just how some of these mechanisms actually work, but it still seems to be unfair to me. Thank you for your time. -- Kent Gregory V.P. - Strategic Account Development Herco Technology Corp. Pho:(858)679-2800 ext.155 Fax:(858)679-7565


Author: "Paolo Angelo" at Internet Date: 04/28/2000 3:03 PM Normal TO: RULE-COMMENTS at 03SEC Subject: stop selective disclosure ------------------------------- Message Contents please stop selective disclosure. thank you. wash hamilton


Author: "Charmen Hummel" at Internet Date: 04/28/2000 6:57 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Right-on SEC ------------------------------- Message Contents Proposed legislation FD - full marks and it is about time that all investors have a level playing field. Stop the old school tie network and let the market become truly fair to all. C Hummel


Author: "Jimenez; Rick" at Internet Date: 04/28/2000 7:36 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7 - 31 - 99 ------------------------------- Message Contents I oppose the passage of this regulation. Richard Jimenez Chubb Computer Services 651 Route 1 s. North Brunswick, NJ 08902


Author: "Mohammad Khan" at Internet Date: 04/28/2000 12:09 PM Normal TO: RULE-COMMENTS at 03SEC Subject: PROPOSED RGULATION FD: ------------------------------- Message Contents I AM IN FAVOR OF "RULE NO. S7-31-99" MOHAMMAD KHAN 04/28/99


Author: David Klausmeyer at Internet Date: 04/28/2000 2:39 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Comments on 34-42259 ------------------------------- Message Contents Securities and Exchange Commission Washington, DC Dear Commissioners: It is quite unfair that 100 or so analysts and large investors are given inside information during these conferance calls when 10,000 other shareholders have no clue what is going on. The only fair system would be to stop trading during these conferance calls with the Company issuing a press release highlighting all the good and bad news diseminated during the call before trading can resume. Secondly place the entire conferance call on a web site and record it for play back on a certain phone number, and schedule the conferance calls monthly on a certain day i.e. first Tuesday, etc. so that all investors could participate should they so choose. Sincerely, David M. Klausmeyer 288 Litchfield Lane Houston, Texas 77024


Author: at Internet Date: 04/28/2000 12:35 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective Disclosure ------------------------------- Message Contents Would rather have accurate information then have to deal with unsubstantiated rumors being floated. Please pass this rule. wolfgang mann


Author: at Internet Date: 04/28/2000 5:03 PM Normal TO: RULE-COMMENTS at 03SEC Subject: RULE CHANGE ------------------------------- Message Contents I WANT THE RULE ENDED JOHN MASTERSON


Author: Lee McCrumb at Internet Date: 04/28/2000 2:43 PM Normal TO: RULE-COMMENTS at 03SEC Subject: New SEC disclosure rules ------------------------------- Message Contents Please let it be known that I am in favor of new fair disclosure rules to individual investors. J. L. McCrumb, President Laser Analytical Systems, Inc. 3333 Bowers Ave. Santa Clara, CA 95054


Author: at Internet Date: 04/28/2000 12:34 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Open Information for Investors! ------------------------------- Message Contents Once again, the SEC is limiting information to the investor by allowing investment analysts the most open and timely corporate information instead of simultaneous and full disclosure for all. Thanks for offering to protect us poor, ignorant, emotional investors by keeping us in the dark "for our own good." To me it's just another version of the IPO stance the SEC takes. "Golly, the little ol' SEC can't do nothin' bout it if that big ol' underwriter wants to reserve IPO shares for their favorite investors! Guess you little guys are just too poor to be allowed to play! Your're just lucky we let you buy shares later, after the big profits are made, of course!" Come on, guys. Everybody's whatching this one. Make equal & simultaneous information available to all. Investors will continue to lose faith in the SEC, and so the stock market, when they are treated as second class players and purposely kept uninformed. Linda McDaniel Eugene, OR


Author: Ben Miller at Internet Date: 04/28/2000 4:29 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Equal access to information ------------------------------- Message Contents Members of the Securities Exchange Commission: I write in strong support of regulations requiring that companies make their financial information available to the public at the same time as they make that information available to members of Wall Street institutions. The current system, which keeps the public in the dark, violates the basic principles of democracy and right to information. A privileged class has special access to time-urgent information. Institutional investors wield enough influence over the markets without granting them the informational leverage to run up prices on privileged information, leaving individual investors chasing the trends. I hope your reform of this situation comes to pass. Benjamin Miller


Author: Sven Nilsson at Internet Date: 04/28/2000 12:07 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective disclosure ------------------------------- Message Contents Failure of Chairman Leavitt's Selective Disclosure proposal would be a failure of "the individual investor's advocate." --Sven J. Nilsson A small individual investor


Author: "Russell O'Grady" at Internet Date: 04/28/2000 3:33 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Comments ------------------------------- Message Contents Are you people out of your minds? What makes you think the general "investing" public cannot handle the information provided to brokers? Get with the program folks or the first time someone loses his or her savings investment due to a ridiculous ruling such as you now propose - you'll be faced with public outrage, not to mention lawsuits "up the wazoo". In addition, public confidence will drop and the market will fall like you wouldn't believe. Sincerely, Clyde R. O'Grady III


Author: "Lee St. Peter" at Internet Date: 04/28/2000 11:08 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Comment on proposed Reulation FD ------------------------------- Message Contents As a small investor looking to build retirement income since my spouse and I have no retirement plans through our employers, I think the SEC should oblige companies to disclose material facts to the public at large rather than to a select few (chosen) within the professional investment inner circle. Fair is fair. L. St. Peter ************************************* " Real Estate is my Business " LEE ST.PETER, GRI Prudential Carolinas Realty 3933 Arrow Drive Raleigh, NC 27612 Tele: 919-782-5502 VM: 919-645-2521 Fax: 919-782-2940 Web Page: http://stpeter.home.mindspring.com E-mail: stpeter@REALTOR.com ***********************************************


Author: "Steve Phare" at Internet Date: 04/28/2000 1:30 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Regulation FD (Fair Disclosure) ------------------------------- Message Contents Dear Chairman Levitt: I strongly support Regulation FD. In the early 1970's, I invested considerable time and finances in the stock market. However, because the brokerage house I was dealing with was not upfront with me; I made some very bad decisions. It has only been because of the advent of the internet which enables me to engage in my own research that I dared investing in the stock market after a 25 year cessation. I adamantly support full and fair disclosure of all publicly traded companies over the internet and by public press releases. I would also like to see a regulation that would require companies to also make their conference calls open to all interested parties. Thank you for giving me the opportunity to comment. Steven C. Phare email:sphare@gjct.net


Author: at Internet Date: 04/28/2000 8:33 AM Normal TO: RULE-COMMENTS at 03SEC Subject: selective disclosure ------------------------------- Message Contents For an organization which is charged with prosecuting investors for trading on inside information, to allow selective disclosure of information is a gross violation of common sense and rationality. It is government protected sinecure for those organizations which qualify, allowing them to profit from " inside information". It is, in my mind , inexcusable. Dave Rawson 1066 Woodland Meadows Dr. Vandalia, Oh. 45377


Author: at Internet Date: 04/28/2000 4:12 PM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No.S7-31-00" ------------------------------- Message Contents I believe that individual investors should get company news at the same time as the analysts. Rich Rhodes


Author: "James Rossi" at Internet Date: 04/28/2000 8:03 AM Normal TO: RULE-COMMENTS at 03SEC CC: ltiger@prodigy.net at Internet CC: jim@thewoodhills.com at Internet Subject: Proposed Regulation FD: File # 57-31-99 ------------------------------- Message Contents Securities & Exchange Commission: I am writing to support full disclosure of business information to the investing public. The dynamics of public ownership have changed. America's competitive success has always been dependent on enterprise & ownership. In decades past, this often took the form of small family-owned businesses. Increasingly, they have been supplanted by large companies. However, the American public continues to own its businesses. Over 50% of Americans own shares of these publicly traded companies, retaining & increasing their stake in the economic & social progress of the country. Owners & prospective owners require all pertinent information on all public companies. The information revolution has empowered all motivated Americans & accelerated the growth & progress of our society. Full disclosure will foster that trend, accelerating investment to the best corporations & upstart young companies, making markets more efficient. In the long run, it will decrease short-term market volatility. Information is power, & full disclosure will ultimately favor long-term investing over short-term speculation. JIM ROSSI RUTGERS UNIVERSITY james_rossi@hotmail.com


Author: "peter sabean" at Internet Date: 04/26/2000 11:34 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Rule on Selective Disclosure ------------------------------- Message Contents I am an individual investor and generally support the idea of prohibiting selective disclosure. I think having information available to individuals and institutional analysts equally is sensible and will bring more investor confidence to the markets. I think care should be taken though, not to over-regulate businesses in the process. I would worry about government micromanagement, oversight and potential corporate liability regarding what information is or is not considered "material". I see in the news reports an ongoing dialogue about this aspect which I believe is important and could be resolved. Peter Sabean Sabean Design


Author: "Charles" at Internet Date: 04/28/2000 4:17 PM Normal TO: RULE-COMMENTS at 03SEC Subject: ------------------------------- Message Contents This should be a no brainer. The investing public should not be discriminated against. Investors should have full and timely disclosure. They, investors, are not being paid to be analysts. The arguement that investors are capable of understanding all items on financial statements is not just reason for discriminatory dissemination of information. If investors suffer from improper investment decisions than it should be there decision as to continuing in the investment arena. Charles Schmidt email: charles@bshinc.com


Author: "Jeffrey Schwartz" at Internet Date: 04/28/2000 2:37 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective Disclosure ------------------------------- Message Contents I have been an individual investors as well as a buy-side analyst on Wall Street and the bias of the SEC in this matter concerns me. I do not believe that the general public should be allowed the same access to companies that professionals have. The reasoning is quite simple: The general public is not in a position to understand the information. If we include the general public in all information releases from companies, the information will by necessity be "dumbed down" and the most important information will be unexplored. As an example, when I called on a company to ask specific questions to flesh out my earnings model, I asked questions the general public would never think to ask. I spent hours of work on models after being trained for years on their construction. I would tend to doubt that the average investor has spent the smallest fraction of that time in financial analysis. Does this person deserve to have immediate access to my conversations with a CFO? Would the CFO even be allowed to take my call? If I cannot have the conversation, how can I fulfill my fiduciary responsibility to my funds clients? How could I make investment recommendations without that specific knowledge? I believe we have all seen how little the general public knows about finance and investing. They certainly do not understand the nuances of GAAP nor the econometric models used in researching equities. Mr. Greenspan commented recently that he did not believe most "investors" could distinguish what they were doing in the stock market with a trip to Las Vegas. I agree. This is precisely why allowing them into the analyst conference calls would be a mistake. As far as I understand the role of the SEC, it was created to protect the individual, uninformed investor. I took several examinations concerning, and placed my signature on papers attesting to my belief in the, SEC's regulations. I promised to abide by these rules, which restrict my investing activity. I am not allowed to invest in certain securities without clearing my trades through my compliance department. This is a huge disadvantage to me but I accept it because I believe in this rule's importance. I believe the vast majority of analysts hold the same view. Of course there will be people who take unfair advantage of inside information but these people are few and far between. I do not believe most of the inside information is even passed through professional channels. Most would come on the golf course or at a dinner party. Should analysts be allowed to intrude on the conversations held by a CEO and his golf foursome? Should all directors of publicly traded companies be required to wear microphones at all times so that everything they say is broadcast to the public immediately? In summary, I believe the information flow can be improves to make markets more efficient but this idea is ill-conceived. The SEC should be vigilant and prosecute insider trading harshly. This is the deterrent. Allowing equal access to financial information will not cure the problem at all. It will only serve to make markets less efficient by reducing and delaying the pertinent information flow from public companies. This is precisely the opposite of what the financial markets require to be stable and trustworthy. Jeff Schwartz


Author: "Ronald Slaughter" at Internet Date: 04/28/2000 2:22 PM Normal TO: RULE-COMMENTS at 03SEC Subject: ------------------------------- Message Contents Please let us all know the same information. How can we be informed investors if we are kept in the dark? What happened to the insider trading rules, sounds like they are getting squished to me. Ellen Slaughter


Author: "Smith; Carol Ann" at Internet Date: 04/28/2000 4:25 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regualtion FD: File No. 57-31-99 ------------------------------- Message Contents Please end selective disclosure!!! The general public deserves to have the information that is sent to analysts. They haven't done anything to merit this special treatment. End it NOW!! C.A>Smith


Author: at Internet Date: 04/28/2000 11:35 AM Normal TO: RULE-COMMENTS at 03SEC Subject: More Disclosure! ------------------------------- Message Contents To the SEC: I think it is time to democratize the decision-making for all investors. It feel that it is undemocratic to allow corporations to disclose certain information only to those that can use it to increase the profitability of their own large investments. Us small investors are not uneducated or stupid. We can and need to have all the information that anyone else has. The professional investment community has had it their way long enough. Sincerely, Holger R. Stub


Author: "Ronmar" at Internet Date: 04/28/2000 2:10 PM Normal TO: RULE-COMMENTS at 03SEC Subject: info ------------------------------- Message Contents Wall street already has enough advantage. Please don't give them anymore. Let the little guy have some level playing field.. This is already an admistration for the elite. I am an average citizen. I would like a fair chance. Sincerely, Ron Taylor


Author: "Terwey" at Internet Date: 04/28/2000 1:27 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File no. S-7-31-99 ------------------------------- Message Contents I agree with the proposed change. Selective disclosure is grossly unfair. Everyone should have access the SEC files at the same time. Thank you. Edith Terwey Route 4 Box 122 Long Prairie, MN 56347


Author: Earleen Thomas at Internet Date: 04/28/2000 6:52 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. ------------------------------- Message Contents The point is freedom of information! I vote YES on new rules to combat selective disclosure of information by public companiesAs a part owner of a company, I have a right to know what is happening even before analysts do. I am an insider and have a right to make decisions about my investments without the filters of others' interests! Please don't let the big money firms and lobbyists rule this area, too. Earleen R. Thomas


Author: "Scott Turner" at Internet Date: 04/28/2000 4:09 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Dear Big Brother, Please stop selective disclosure ------------------------------- Message Contents Dear Big Brother - I am a big boy and can be trusted to interpret information. Why you think that analysts and mutual fund managers (90% of whom under perform the market) are entitled to full financial disclosure, but I, an individual investor, citizen and voter cannot be trusted - is simply beyond comprehension. My freedom is more important than your protection. Scott Turner


Author: "Joe Ball" at Internet Date: 04/28/2000 11:41 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Lets Stop Selective Disclosure ------------------------------- Message Contents Dear Sir, Its 11:40 PM in Honolulu, where i live. I favor Proposed Regulation FD: File No. S7-31-99. Please apply it. sincerely, Joseph A. Ball Customer Retention Manager Servco Pacific Inc. Honolulu, Hawaii


Author: Gary Bottemer at Internet Date: 04/28/2000 5:10 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rules Change ------------------------------- Message Contents I favor proposed regulation FD: File NO S7-31-99 Let everyone have the same information at the same time Gary D. Bottemer


Author: "Kimberly Burger" at Internet Date: 04/28/2000 7:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: ------------------------------- Message Contents Gentleman and Ladies: I am a small investor in stocks and mutual funds. It has come to my attention that select financial professionals are privy to information before individual investors and others. One of the devices through which this is done is conference calls and even, I am told, preferred access to financial statements. These practices should be prohibited. It skews the market and gives select people and entities an unfair advantage. /s/ Chris Capozzi


Author: "J. Derting" at Internet Date: 04/28/2000 10:27 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Selective Disclosure ------------------------------- Message Contents To Whom It May Concern: As individual investors, we are very much opposed to the unfair practice of "selective disclosure". Sincerely, Joe and Jan Derting Abingdon, Virginia


Author: at Internet Date: 04/28/2000 11:15 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. ------------------------------- Message Contents I favor Proposed Regulation FD: File No. S7-31-99 Anita Gard 3154 Laurel Grove South Jacksonville, FL 32223

Author:   at Internet
Date:    04/28/2000  9:22 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg FD:File No. 57-31-99
------------------------------- Message Contents 
I'M OPPOSED!
     
Edith C. Nelson

Author: at Internet Date: 04/28/2000 8:54 PM Normal TO: RULE-COMMENTS at 03SEC Subject: selective disclosure ------------------------------- Message Contents Gentlemen, I fully oppose the selective disclosure bill-lets think twice! Keith T. Helmer


Author: "Robert Proctor" at Internet Date: 04/27/2000 2:02 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31- ------------------------------- Message Contents Wall Street should not condone Machiavellian obstacles to free markets. Brokerage firms, pundits in the ear of government (cp., lobbyists, cp., SIA), and over-regulation are dangerous servants and fearful masters. Perfect markets need perfect and equal information. Adam Smith's "invisible hand" applies: Human progress is empowerment of the individual. A measure of wealth is the number of quality choices available. Please endorse the Proposed Regulation FD: File No. S7-31-99 to allow investors the information to make quality choices. Sincerely, Robert Proctor


Author: at Internet Date: 04/28/2000 11:33 PM Normal TO: RULE-COMMENTS at 03SEC Subject: level playing field ------------------------------- Message Contents I would like to see that retail investor like me will be given the same opportunities and previliges accorded to the big guys, the institutional Investor. Edita G. Sanderson P.O. Box 43-167 Port Hueneme, CA 93044


Author: "jSchumac@earthlink.net" at Internet Date: 04/28/2000 11:19 PM Normal TO: RULE-COMMENTS at 03SEC Subject: ------------------------------- Message Contents I favor Proposed Regulation FD: File No. S7-31-99" is probably sufficient. John Schumacher


Author: at Internet Date: 04/28/2000 11:01 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation File No. 7-31-99 ------------------------------- Message Contents The public really is intelligent enough to handle the same news as people within the investment industry Please allow us the same opportunity. Carol Simone


Author: jack/martha sisko at Internet Date: 04/28/2000 9:06 PM Normal TO: RULE-COMMENTS at 03SEC Subject: selective disclosure ------------------------------- Message Contents I favor Proposed Regulation FD: File No. S7-31-99 jack sisko


Author: csylva@webtv.net (Christine Sylva) at Internet Date: 04/28/2000 11:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: New regulaton ------------------------------- Message Contents I support the new reg. to make any information available to ALL interested parties, rather than the "insider" system now in effect, concerning company and institution fiscal status. Thank you! Christine Sylva


Author: "John Turner" at Internet Date: 04/28/2000 10:02 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. 57-31-99 ------------------------------- Message Contents It seems intuitive to me that companies should make equal disclosures of information to individual investors and investing institutions. I can't conceive of a rational argument as to why an institution should be privy to vital information which would be kept (or delayed) from an individual investor. Thanks! -John Turner MD, johnturner@pdq.net

http://www.sec.gov/rules/0428b01.htm


Modified:05/09/2000