Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: "Larry E. Abbott" at Internet
Date: 04/22/2000 7:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation
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Proposed Regulation FD File No S7-31-99
I support passage of this regulation.
Larry E. Abbott
Author: "albany fam" at Internet
Date: 04/20/2000 7:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposal Regulation FD: File No. S7-31-99
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I fully support the proposal for fair disclosure of information by publicly
traded companies to the public. It is unethical for companies to leak important
information to the Wall Street analysts without also giving that same
information to the public. Individual investors should have the right to be as
fully informed about publicly traded companies as any analyst. It's ludicrous
for the SIA to insinuate that individual investors are not willing nor capable
of researching and understanding the companies we invest in. Please vote to put
Regulation FD in effect. Fair and full disclosure will benefit a majority of
investors. Thanks for your time. Debra Albany.
Author: WAlbin5234@aol.com at Internet
Date: 04/22/2000 10:24 PM
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TO: RULE-COMMENTS at 03SEC
Subject: FULL, IMMEDIATE, PUBLIC DISCLOSURE
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NOTHING LESS IS ACCEPTABLE. AS AN INDIVIDUAL INVESTOR I EXPECT NOTHING LESS
THAN MY SUBJECT TITLE. I CHOOSE MY OWN STOCKS. I DEMAND A LEVEL PLAYING
FIELD. LET THE BROKERS AND ANALYST'S, MARKET MAVENS AND MAKERS HAVE THE SAME
INFORMATION AS US INDIVIDUALS GET AND LET THEM HAVE IT AT THE SAME TIME.
Author: Tim Badley at Internet
Date: 04/22/2000 2:50 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
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I am in favor of the proposed regulation FD. The
arguments presented by the SAI are nothing more than
an attempt to hang on to their "preferential"
connections with corporate America, which secures
their "first mover status" in regards to company news.
If you consider that some of these analysts and media
are actually excluded from some of the larger, more
private "meetings", you would think that they, too
would want full disclosure to even them up with the
"big guys".
Again, I am in favor of the proposed regulation FD.
Tim Badley
Author: at Internet
Date: 04/22/2000 10:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD File#s7-31-99
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Dear Sir/Madam,
I am in favor of this long needed regulation.I pay commissions to these
brokers in my case Dean Witter in Los Gatos Ca. Why should they have an
opportununity to unload stock on anyone or buy stock before their customers
or anyone for that matter.
It is not legal for me to trade on inside information why should it be legal
for them.
I am tired of being prey for the broker sharks and a victim of firms with
inside information.
All I want is a level playing.They want the playing field tilted in their
favor.
Regards,
Warren Bates
Author: tom brian at Internet
Date: 04/22/2000 10:30 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Pending Regulation FD: File No. S7-31-99"
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If those that do the analyzes of the companies of the usa and the world
are good at their job they should not fear that others can see the
information that they base there decisions on , the fact they are
setting in the right place should not mean that they should have first
dibs on information that the rest of the people will get second hand
,later or not at all.
Author: at Internet
Date: 04/22/2000 10:17 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support strongly the proposal to open the disclosure to the public of
information by publicly traded companies. The argument by the SIA that
such a move might not be beneficial to the public is an old one used by
privileged organizations in times present and past (e.g. the Learned in
Europe used just such an argument against Gutenberg's printing press -
imagine had they been successful).
The move to increase dissemination of information can be only good.
Yes, some people might misinterpret information. But then, as anyone
who is active in the market knows, the analysts do so too on a regular
basis. Additionally, analysts are often constrained in their
proclamations by their own special interests (e.g., how often does one
see an outright sell signal from an analyst?).
Regardless, the individual who stands to gain or lose the most then will
have the most immediate information available to him/her, without a
possible layer of other peoples' biases, misinterpretations and special
interests distorting that information before he/she gets it.
Thank you for taking the time to review public comments on the matter.
Christopher F. Broadbent (cfb@austin.rr.com) - an individual/private
equity investor.
Author: "David A. Brotton" at Internet
Date: 04/22/2000 5:50 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File No. S7-31-99
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As a small individual investor, I want to express my very STRONG support
for the above proposed regulation.
Sincerely,
David A. Brotton
Author: Simon Butler at Internet
Date: 04/22/2000 4:24 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation
FD: File No. S7-31-99
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Proposed Regulation
FD: File No. S7-31-99
hi,
i have read with interest the comments made recently by the Ad Hoc
Working Group
on Proposed Regulation FD and the Legal and Compliance Division of the
Securities Industry Association ("SIA"). the suggestion is that they
can perform
the analysis and reporting of public company financial disclosures in a
more
useful and compelling manner than the individual investor and as such
argue
that the present system of "secret" disclosure to a select group of
analysts
should continue.
i find the above completely absurd. i think it is pretty clear that
these
analysts are more interested in preserving their lucrative business at
the
expense of the individual investor by means of insider information.
i implore you to strike this rule from the lawbooks and level the
playing
fields for all investors.
rgds, Simon Butler
Author: at Internet
Date: 04/22/2000 6:39 PM
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TO: RULE-COMMENTS at 03SEC
Subject: rule S7-31-99
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to whomever might be concerned
i strongly support the approval to this rule , we have to work toward a fair
market that guarantees (not only through the SEC vigilance) equal
opportunities to everyone and no advantages to selected ones.
I already dream of a market that has computers regulating the daily activity
instead of "human" specialists, but i understand that to be quite down the
road from now , even if not non-achievable one day.
The public is getting more and more frustrated as he starts to understand
that as a private investor he always will come second to hear about important
facts concerning his investments and by the time he gets to know things the
event has already caused the reaction leaving him even more frustrated. Of
course as long as we are in a bullish market ( are we anymore) the average
investor wont complain , but as things will turn around i will not be
surprised if lawsuits or reports by the press will come down as snowflakes in
a winter storm.
Such a rule is a first but important step toward more fairness, needed ,
almost necessary in a world that sees an ever increasing cash affluence from
an even increasing number of private investors.
regards
stefano calenda
Author: at Internet
Date: 04/22/2000 8:30 PM
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TO: RULE-COMMENTS at 03SEC
CC: Rcampbellx@aol.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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Gentlemen:
It has come to my attention that some in the securities industry object to
the proposed requirement to simultaneously disclose relevant information to
securities analysts and to the public by making important information widely
available to the financial reporting industry. One of the arguments has been
that the public is not able to adequately assess the information.
The issue is not whether individuals can or will use the data that is
disclosed. By compelling wide access to the data, the wider body of reporters
and analysts will analyze and report the data to a much larger segment of
those affected by the financial markets.
The issue is simply one of fairness. The SEC should be concerned that the
system does not continue to allow a few to profit by earlier access to what
is essentially "insider" data.
The SEC should not be concerned about whether individuals are able to
understand the implications of that data. The financial press and the
analysts who serve the public investors will ensure that the data is quickly
analyzed and made available to the public in a form that is useful to those
who may be affected by it.
I am an investor who relies on data from many sources. There are thousands
like me. We should not be placed at a disadvantage to a few who have special
access to important information about the companies that we own.
Best Regards,
Robert J. Campbell
25 Scollay Circle
Salem, NH 03079
Author: "dennis carman" at Internet
Date: 04/22/2000 10:06 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir:
I have just read the comments from the Securities Industry Association.
Efficient markets demand full and open access to information by ALL markets
participants. This fact alone demands that companies treat all investor
equally. I am in full support of immediate, and full, disclosure. Limiting
information creates a less efficient market, a more volatile market, and creates
a benefit for a single class: analysts.
I am a full-time air traffic controller studying accounting for my second
career. I do not have the immediate fluency with all analytical tools. I can
learn, examine, and understand data and reach a rational conclusion. All this
is accomplished without a single analyst. If an analyst proved economical, of
course I would use his/her services for my investment decisions.
Sincerely,
Dennis Carman
Author: at Internet
Date: 04/22/2000 8:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am appalled at the arrogance of the Wall St. analyst community!!
I feel I am entitled to full disclosure from public comanies at the same time
they impart information to the analysts.
I also think that anyone who comments on public companies' stock should be
required to disclose any financial interest he or she has in the company.
The shameless hyping of stock by "guests" on CNBC and others by people who
do not disclose their interest in the stock is outrageous!!
If their firm has gained financially from selling or underwriting it should
be disclosed to audience. If the commentor is long or short the stock it
should be disclosed as well.
I think most people think this is being done at this time because it is so
clearly the right thing to do. They would be sickened to find that they've
thought all along that this was being done and it isn't.
Individual Investor
vince carolan
Author: "Dave Cook" at Internet
Date: 04/22/2000 8:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject:
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Dear Sir;
I think it is the right of all investors to have access to the same information
and I do support Proposed Regulation FD: File No. S7-31-99. Thank you for your
time.
Sincerely
Jonathan D Cook OTR/L
Author: "Ilene Courland" at Internet
Date: 04/21/2000 6:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am for full disclosure of companies' information to the public. The
analysts want all the insider information for themselves to encourage
dependency on their opinion and their mutal funds, like legalese is
deliberately incoherent to the "average" person to encourage people to pay
their lawwyers $500 an hour. Please make it accessible to the rest of us.
Ilene Courland
58 Haig Road
Valley Stream, NY 11581
Author: "Todd Dipaola" at Internet
Date: 04/22/2000 6:44 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom it May Concern:
This proposed regulation would finally give the public the amount of
responsibility that would lead to greater public scrutiny. Currently by
"baby-feeding" the public information based on analysts recommendations forces
the public to not interpret their own information. When the public never
evaluates information because it receives other viewpoints, it perpetuates
investor ignorance. And clearly it is investor ignorance which leads to
inefficient markets.
Also current conditions undoubtedly leads to unfair insider trading from major
Wall Street companies who are privy to information before the public.
I strongly urge you as a citizen and an investor to approve this regulation that
would further direct the market to Main Street and further this country's
principles of democracy.
-Todd Dipaola
Author: at Internet
Date: 04/22/2000 10:13 PM
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TO: RULE-COMMENTS at 03SEC
Subject: FD: File No. S7-31-99
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Gentlemen:
Please pass this. I see no argument that makes withholding information from
the general public a detriment to an orderly market. Denying this opportunity
is in my opinion an insult to the spirit of a free market.
Fred Dryg
1228 Lyon St., NE
Grand Rapids, MI 49503
(616) 456-9897
fredoit@aol.com
Author: at Internet
Date: 04/22/2000 10:59 PM
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TO: RULE-COMMENTS at 03SEC
Subject: (no subject)
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Dear Sir, Ms. etc.
I do support a more level playing field in regard to the dissemination of
information regarding publicly traded companies. What is the difference if an
insider provides this information to an analyst or a friend of his. It is
priviledged information and as such is an analyst more entitled than an
actual shareholder or potential shareholder? I think not or maybe we just
wouldn't under
stand it anyways. I'd prefer to make that judgement however. I believe there
is potential for litigation here. Freedom of information may loom large in a
court of law. Level the playing field or we as individual investors are going
to demand why! Thank-you.
Respectfully,
Dr.Paul A. Edwards
Author: Ken Elpus at Internet
Date: 04/22/2000 10:25 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Members of the Commission:
I would like to add my voice in the debate over Proposed Regulation FD, the
so-called rule to "level the playing field" with regard to analysts
receiving what amounts to be privileged information in advance of the
general public.
This rule would be a tremendous step in aiding the current trend in the
marketplace -- that is, the empowerment of the individual investor over the
full-service brokerage. The idea that the current system of allowing the
analysts access to information prior to public disclosure is good for the
markets is ludicrous.
The Securities Industry Association has purported that analysts "perform a
necessary and very valuable function in the U.S. capital market...[by
being] the principal way in which important financially significant
information...effectively reaches most investors." They have also claimed
that analysts' "work results in more continuous disclosure, fewer
surprises, and less volatility."
Analysts do none of these things. Analysts create volatility and surprises
by their very nature. Analysts create volatility by changing their
recommendations and ratings at what appears to be a whim, and generally
after material information has been disclosed to the public. Analysts
create surprises when companies return earnings reports that either exceed
or fall short of analyst expectations. If the current system were truly
advantageous, the "earnings surprise" that will so often give a stock a
short term pop up in price would not exist.
The SIA has also claimed that analysts spend much time "ferreting out
negative information" that a company would rather not disclose. This is
simply untrue. If this were so, then the recommendation term "sell" would
be used. It almost never is. Wall Street's experienced know that analysts
never recommend "selling" a stock. They only recommend "Strongly Buying,"
"Buying," "Neutral," and "Hold." Heaven forbid an analyst recommends
"Shorting" a stock. This is because the analysts know that they have
access to privileged information and the company may inhibit that access if
a negative initial (or subsequent) rating causes a stock price to fall.
Levelling the playing field and allowing all parties access to all
information is not only in the spirt of the free market system, it is
shocking that it has taken the SEC this long to even consider it.
Proposed Regulation FD should become reality.
Kenneth Elpus
Chief Financial Officer
Mixed Signals, LLC
--
"Life is a tragedy to those who feel, a comedy to those who think."
-- Horace Warpole
Author: "David Goss" at Internet
Date: 04/22/2000 6:23 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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As an individual investor, nothing is acceptable but Full Disclosure.
David Goss
Author: "Tim Caudill" at Internet
Date: 04/22/2000 2:51 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No S7-31-99
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Dear SEC Officer,
As an individual investor, I strongly encourage you to enact the above
regulation, which would require corporations to disclose important
information to the public. If corporations disclose important information
to large brokerage firms solely, it gives those firms and their clients an
unfair advantage in regards to trading equities. With so many individual
investors in the market, we should all have access to the same information.
Thank you,
Linda Gunshefski, MD
625 Catherine St
Walla Walla, WA 99362
Author: "David J. Gustafson" at Internet
Date: 04/22/2000 7:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Sirs:
Level the playing field!!!! The public has every right to the same information
at the same time as the analyst.
David J. Gustafson
Author: "Conley T. Gwinnn" at Internet
Date: 04/22/2000 8:53 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To assume that I am willing to stake my financial future on second-hand
information, stripped perhaps of issuer spin, but with the analyst's spin
imposed instead; while often in direct competition with the trading interest of
the analyst's corporate sponsor; is to assume that I am devoid of any
intelligence whatsoever. The primary function served by most high-profile
analysts is self-enrichment and self-aggrandizement. Given that the stock market
is essentially zero-sum in the short term, those enrichments must come at my
expense.
Why would ANY reasonable person doubt that I would be better served by equality
of information?
Conley T. Gwinn
318 W. Maple
Byron, Michigan 48418
conleytgwinn@email.com
Author: at Internet
Date: 04/22/2000 6:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I would like to express my wholehearted support of fair and timely public
disclosure of publicly traded companies.
It is clearly the most democratic approach and this regulation is in the
best interest of those whose capital is at risk.
Namely, the individual investor.
thanks,
G. Hartzog
Author: "Paul Herr" at Internet
Date: 04/22/2000 7:07 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD file # S7-31-99
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Please accept my opinion that this is a necessary regulation.
We do not need Wall Street people hearing the reports from companies before
we, the general public get the word fromthe company.
We can analyze prospectuses and call the company ourselves.
Thank you
Paul Herr
Author: "tj" at Internet
Date: 04/22/2000 9:54 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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While it makes sense that stock company analysts should be allowed to
interview privately the management of a company with regard to
announcements, the material gleaned there should be available to the
stockholders just as anyu important announcement of a company should be
available to that company's stockholders. To suggest that stockholders
should not be privy to information or to suggest that "...individual
investors...poring over prospectuses and periodic reports is...out of sync
with the real world" is an insult to all investors and should lead the SEC
to seriously question the veracity and motivation of the SIA.
Timothy F Jenkins
individual stockholder in multiple companies who can READ!
Author: at Internet
Date: 04/22/2000 7:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am wholeheartedly IN FAVOR of Proposed Regulation FD. That a very limited
group of Wall Street analysts is allowed special access to information is the
height of unfairness.
Those who benefit from special access to information under the current system
naturally oppose this regulation. They would have us believe that the general
public is too uneducated to make decisions based on direct, unfiltered
information. They advance the preposterous notion that less information is
better than more, and that by controlling the flow of information to the public,
and in the process spinning it according to their own biases and hidden agendas,
they are somehow providing something of value to the average investor and the
market as a whole.
The SIA claims that "The alternative model of millions of individual investors
and potential investors poring over prospectuses and periodic reports is highly
theoretical and out of sync with the real world." First of all, I disagree.
But regardless of whether this is a true statement or not, how does it follow
that free access to information should not be available to all? What I read in
this statement is the industry's fear that the investing public, whom they claim
to serve, is becoming more sophisticated and has the capacity for independent
thought. They would like to restrict open access to information so that a
public starved of direct access to information is forced to turn to them.
Surely there is a place for analysts. They can take the information that
everyone else available to them and draw whatever conclusions they like. Those
who value their analysis are free to listen to them. But to anoint a privileged
few with special access to information, and to allow them exclusive power over
the acquisition and distribution of this information is decidedly contrary to
the interest of the public at large. the public should be brought to the table.
All who seek information should be allowed equal access.
Best Regards,
Brian Kernek
Individual Investor
In favor of Life, Liberty, and FREE ACCESS TO INFORMATION
Author: at Internet
Date: 04/22/2000 8:29 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD - SIA's filing
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The last 2 sentences of SIA's filing state: "If the (anaylyst's) questions
cannot be asked in private, they may not be asked at all. Is that good for
the market?"
This is an incredible attitude displayed here by SIA. If an analyst casn
obtain priviledged information in response to "private questions" doesn't
this release of priviledged bad for all other investors not privy to the
information? Does Anyone really believe that important information received
by an analyst will not be immediately passed on to his firm's priviledged
investors to the detriment of all other investors.
Bill De Keyser
23 Doheny
Laguna Niguel CA 92677
Author: John Martinez at Internet
Date: 04/22/2000 8:42 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Level the playing field and allow individual investors the *same* access
to information about publicly-traded companies.
I take great offense at the view of the Legal and Compliance Division of
the Securities Industry Association ("SIA") that individual investors
are incapable of accurately processing information from these companies.
John Martinez
Individual Investor
Denver, CO
Author: at Internet
Date: 04/22/2000 9:27 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern:
I am writing in support of proposed regulation FD. It is only through the
free flow of information that securities and stocks can be fairly priced. If
analysts are given information on a preferential basis this creates an unfair
competitive edge against millions of individual investors. Many of us do take
the time to research our investments without the bias of professional
analysts and deserve the timely free flow of information concerning the
companies which we have invested. Our investments are just as important as
anyone else's and we deserve to know all relevant information about these
companies, not just what analysts want us to know with the "spin" that they
choose to put on the information.
This is important for the individual investor and I urge you to support this
regulation.
Regards,
Bruce Mathern MD
Author: "Richard Matthews" at Internet
Date: 04/22/2000 8:31 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Hello,
I see that the time for comment has been extended.
I have had time to review the SIA input and would like to make a few additional
comments.
It is my belief that those individual investors who are not "poring over
prospectuses and reports"
are probably investing in mutual or index funds. (I think it is easier to look
at prospectuses of one or two funds rather than individual stocks as I do.) I
don't have a problem with this "poring" effort and would not
invest without doing same.
From my corner, I have seen very little, if any, negative information on
companies passed along by analysts.
It seems as if one has to get a feel for each analyst, and determine how much to
discount his/her recommendations.
I believe that many analysts are overconfident in their abilities to analyze
companies. I find it inane (close to insane?) that anyone would claim to
"quantize" a tone of voice, a facial expression, etc. and use this information
as part of a data set in determining how to rate a company.
Thank you for listening to my take on this proposed regulation, which is:
FAVORABLE.
Author: Donald McMurchie at Internet
Date: 04/22/2000 2:52 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I earlier sent an E-mail indicating opposition to this proposed
regulation. This was IN ERROR. My apologies for this mistake.
Please record my support for the prompt passage for this important rule.
Dr. Mc
Don Mc Murchie, Ph.D
Associate Professor
Oregon Institute of Technology
Manufacturing/Mechanical Engineering Technology
(541) 885-1889
Author: bmiller at Internet
Date: 04/22/2000 4:44 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am writing this quick e-mail to give my opinion on the above mentioned
regulation that has been proposed. I think the regulation is good,
specifically the requirement that publicly traded companies release to
the public important information, rather than just releasing that
information to analysts or others the companies see fit. The bottom
line is that these are publicly traded companies. If they want to rely
on the public's money by way of stock issues then all the information
they have relevant to that transaction must be available to the people
providing the money. The argument that the general public isn't smart
enough to be able to interpret the information and may have a "knee jerk
reaction" is absurd. As a member of the public to trades and invests in
stocks of various companies I for one heartily support any effort to get
more information on any trading and investing decision I may make.
Thank you,
Bill Miller
bmiller@micronet.net
Author: Al Moser at Internet
Date: 04/22/2000 7:38 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support full disclosure and ask you to pass this regulation.
_________________
Al Moser
al@moser.net
http://al.moser.net
Author: "Andrew Muhlbach" at Internet
Date: 04/22/2000 5:14 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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The current wide spread practice of selective disclosure to analysts and
other industry "insiders" undermines public confidence in the fairness and
openness of the securities markets. Selective disclosure undermines this
confidence because individual investors do not receive material information
at the same time as larger institutional investors and the analysts working
solely on behalf of their brokerage's clients. While much of this
information eventually "leaks" out to the investing public, this
differentiation and delay in the dissemination of information is contrary to
the entire purpose of the Commission. The securities markets must provide a
level playing field to ALL investors, not just those who hold large
positions or who are clients of the favored brokerage houses.
Perceptions matter! Whether institutional investors and large brokerage
clients are in fact benefiting at the expense of the average investor is not
the final issue. The investing public currently believes that these
"insiders" are benfitting by their priviliged access to information. That
belief is rational. That belief erodes the public's confidence in the
securities markets. The Commission's core purpose is to regulate the
securities markets in order to ensure actual fairness and to maintain the
perception of that fairness.
The opposition to this regulation voiced by the Securities Industry
Association (SIA) is cynical and self-serving. It is not surprising that
those industry insiders who most benefit from today's practices would urge
the Commission to maintain the status quo.
The SIA, in effect, argues that the investing public is not smart or
sophisticated enough to assess information without the interpretation of
analysts and the financial media. While this assessment is questionable,
this argument is ultimately irrelevant. All investors are entitled to equal
access to material information whether they understand it or not. Those
investors who are capable of understanding information should not be
penalized by any real or percieved shortcomings in the abilities of their
fellow investors. Those investors who need help understanding the
information can seek that help from the media or investment "professionals."
The media and analysts are already well compensated for providing these
services to those who need them. They should not also be rewarded by being
given a monopoly on first access to material information.
The SIA urges that even under the proposed regulation, investors will not get
material information at the same time because some pay closer attention and
can act more quickly than others. From this truism, the SIC argues against
equality of access to information. In so doing, the SIC opposition
misapprehends the purpose of the Regulation and the Commission. Equality of
access to information is the goal not equality of individual cognizence. It
is perverse to argue, as the SIC does, that because some people will always
be able to act more quickly on information that they, the industry insiders,
should be the people who get the information first! Make all information
equally available and let the race go to the swift. Don't give the
instituional investors and brokerages a head start.
The SIC states: "It hardly needs saying that analysts perform a necessary
and very valuable function in the U.S. capital market. They, together with
the media, are the principal way in which important financially significant
information (including information contained in prospectuses and reports
filed with the Commission) effectively reaches most investors and gets
reflected in the marketplace." THIS WILL CONTINUE EVEN IF THE REGULATION
IS PASSED! THERE IS SUFFICIENT FINANCIAL INCENTIVE FOR ANALYSTS AND
FINANCIAL MEDIA TO CONTINUE EVEN IF THEY ARE NOT ALLOWED ADVANCE ACCESS TO
INFORMATION.
The SIC states: "The alternative model of millions of individual investors
and potential investors poring over prospectuses and periodic reports is
highly theoretical and out of sync with the real world." IT IS THE SIC
WHICH IS OUT OF STEP. THE INTERNET EASILY ALLOWS THIS TO TAKE PLACE AND IT
DOES ON A DAILY BASIS. THIS "HIGHLY THEORETICAL" VIEW IS INSTEP WITH THE
MODERN INVESTING WORLD, MUCH TO THE DISMAY OF THE FULL-SERVICE BROKERAGES!
DON"T ALLOW THE LUDDITES TO STEM PROGRESS.
The SIA asserts that under the proposed regulation, less, not more,
information will be available to the market. Even if true, fairness and
integrity of the markets will be increased because everyone will have equal
access to that information. As recognized in the prohibitions against
insider trading, it is fundamentally unfair to allow a select few to obtain
material information and act on it.
In closing, I support the proposed regulation.
-------------------------------------------------------------
Andrew Muhlbach
San Francisco, CA
Individual Investor
> _________________________________
> Subject: "proposed regulations FD: file no. s7-31-99"
> Author: "bear jr." at Internet
> Date: 04/20/2000 8:01 PM
>
>
> dear s.e.c.,
> the information exchange method as it functions pre-sently in
> the
> marketplace desperately needs to be changed.
> the notion that some "wise" financial wizard needs to have
> first access , and that i am too stupid to understand balance
> sheets is not only arrogant, it is wrong and dangerous.
gerald peters
bearjr1@juno.com
Author: "Kathi Poindexter" at Internet
Date: 04/22/2000 7:46 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear SEC,
As an individual investor I would like to see all information disclosed to
the public at large. We may not make our living selling investment advice
to others but that doesn't mean we aren't intelligent enough to make our own
investment decisions. I have yet to get better investment guidance from my
financial advisor than I do when researching for myself and making decisions
based on it. And he gets paid for his advice! I've decided that he (any
paid investment advisor for that matter) will never be able to give me the
best investment guidance because any advice he/they come up with will always
be tempered with what they will make on it. If the best for me means he
makes nothing, or less than he thinks he should, then I'm certainly not
going to be given that advice. We deserve the same information.
There will always be those investors who either don't have the time or
inclination to do the work themselves or who would simply rather rely on
others for their investment advice but that shouldn't mean the rest of us
don't get the opportunity to act for ourselves on the same information. We
deserve the opportunity to be masters of our own investment destiny.
Thank you,
Kathleen Poindexter
Maidens, VA
Author: "Paul Rerucha" at Internet
Date: 04/22/2000 5:48 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe it is important to provide full discolsure to all investors. The
practice of partial disclosure to only a few is not tolerable.
Thanks you.
Paul Rerucha
CEO Ashmead College
Phone: 206-595-2320
Fax: 206-728-8469
shalako@accessone.com
www.ashmeadcollege.com
Author: at Internet
Date: 04/22/2000 9:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Let's level the playing field. I am an independent investor who makes his
own investment decision. It is only fair to give us equal access to
information. Please vote in favor of this regulation.
Dennis J. Saturnino
Author: at Internet
Date: 04/22/2000 10:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear sirs:
I am an individual investor and believe that it is imperative that all
information that is available to any investor, be available to all investors.
Recently, a number of companies allow the public like myself to listen in on
conference calls. The discussion that occurs on message boards following
these conference calls is invaluable in determining how we wish to postion
ourselves in these securities. Requiring all p8ublicly disseminated
information to be available to all investors will make markets more
efficient, keep the small investor informed and keep us from being taken
advantage of by the "big boys." To go one step further, it would be nice if
all investors were notified of these calls, at least those who own the
securities. Although this would lead to greater expenses , it would be a
nice recommendation of the SEC if it is not required.
Sincerely,
Alan Schaeffer
Author: "Sally Spry" at Internet
Date: 04/21/2000 7:42 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I strongly support the passage of Proposed Regulation FD
I have recently retired. Between my 401-K, IRA's and savings we have about
1.5 Million invested in stocks and bonds. This is not enough to make us
"rich"; but invested wisely should allow us to live out our lives
comfortably.
Most of our savings is invested with a full service broker. However, we do
not get individual treatment. Any benefit their analysts receive from
advance information is not shared with us.
Investment houses do not serve my best interest. To succeed in the
investment market I need to hire an investment manager, or be my own
analyst. To accomplish the later I need equal access to information.
I strongly support the passage of Proposed Regulation FD and, among other
things, stop companies from engaging in the practice of discreetly
disclosing important information to Wall Street analysts without also giving
that information to the public at large.
The internet has given us equal access to news sources, now give us equal
access to corporate information.
Thank you for your time and consideration.
William Spry
19 Evelyn Rd.
Stow, MA 01775
Author: at Internet
Date: 04/22/2000 10:22 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
please level the playing field for everyone.
evan swietnicki, investor
Author: "Glenn Thomas - Smashing Ideas" at Internet
Date: 04/22/2000 3:43 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
With regard to the proposed change that would require the fair disclosure of
information by publicly traded companies to the public, I would like to add my
voice in support.
This is an extremely common sense rule that will make our system a fairer and
more open one for all investors. If you continue to give the few an advantage,
it will call into question the nature of our capitalist system. With the rapid
rise of the web as a disseminator of information, the current state of affairs
is that information wants to be free and readily accessible to all.
Thank you.
Yours,
Glenn Thomas
Author: at Internet
Date: 04/22/2000 11:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen:
Familiarity with a variety of market conditions allows me to make
financial decisions which are beneficial to the country and to social
security. Taking responsibility for my retirement funds, I will be less
reliant on the government to support me as I age.
Using the Internet as one financial information tool has been a benefit
to aid in making wise decisions. In my twenty years of investing there was
only one stockbroker who demonstrated obvious wise judgment in advising me as
a client. My access to information was certainly limited so I followed some
of their advice.
It became obvious that they knew something I didn't as the market fluctuated.
Some investors do follow analyst recommendations en masse knowing of
their privileged information. This would seem to exacerbate volatility.
Independent assessment of the publicly shared information would give
diversity to the market.
Individual investors could follow their judgment based on the same
information. A variety of directions could reduce volatility.
Privileged information to a few sounds a lot like monopoly, don't you
think?
Thank you,
Stephanie Tishler
2825 67th St.
Lubbock, TX 79413
Author: Brent Trask at Internet
Date: 04/22/2000 8:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
CC: btrask@sssnet.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Not a lot to say here, this proposed rule simply makes sense. In
fact I thought it was already law. I am sure the professional
community will argue that I the individual investor need to be
protected from my own ignorance. I implore you, move the rule
forward, I want all of the information available to make my own
decisions.
Brent Trask
7924 Chablis Dr NW
Massillon, OH 44646
email: btrask@sssnet.com
Author: Charles Travers at Internet
Date: 04/22/2000 7:58 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
As an individual investor, I am strongly in favor of the proposed
regulation.
Sincerely,
Charles Travers Jr.
Author: "G.R. Vestal" at Internet
Date: 04/22/2000 5:27 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
"Proposed Regulation FD: File No. S7-31-99"
I believe that companies should no longer engage in the practice of
discreetly disclosing important information to Wall Street analysts without
also giving that information to the public at large.
Guy Robert Vestal
Chairman/CEO
Pagan Internet Industries Inc.
Author: at Internet
Date: 04/22/2000 9:35 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I wish to add my support to the proposal for fair
disclosure of information by publicly traded
companies to the public.
As an individual investor, I do not believe it is
fair that Wall Street analysts should be allowed
to receive important investment information ahead
of the general public.
A SEC policy that would benefit all
non-institutional investors will allow the playing
field to be leveled in an environment which is
currently imbalanced.
Thank you,
- Paula Warfield
Individual Investor
Author: at Internet
Date: 04/22/2000 8:06 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: FD: File No. S7-31-99
------------------------------- Message Contents
This prposed rule makes sense. It takes nothing away from the analysts and
gives something to the investing public. The SIA's argument is weak
(laughable) The brokers should hire more competent lobbyists.
Robert H. Weir, an Investor
Author: "Matt Werline" at Internet
Date: 04/22/2000 6:25 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To Whom It May Concern:
As an individual investor, I strongly support your actions to propose
legislation/rules that prevent selective disclosure. With today's
technology, it does not make sense for selective disclosure. The internet's
ability to delver text, audio, and video in a cost effective means
eliminates any justifiable reason companies should be permitted to continue
the practice of selective disclosure.
With selective disclosure it gives select individuals and organizations and
unfair advantage over the smaller investor. The individual investor is "the
last to know" putting them always at disadvantage. The SEC has rules against
insider trading, and this should be considered no different. Selective
disclosure only creates a different level of insiders.
Selective disclosure is not fair to individual investors because it creates
an uneven playing field, and it no longer makes since in this highly
connected world.
Yours very truly,
Matt Werline
Powell, OH
Author: "JOEL T WHITENER" at Internet
Date: 04/22/2000 3:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I strongly recommend your adopting the Proposed Regulation FD: File No.
S7-31-99. It is incomprehensible to me that analysts are able to get
information, but the general investing public are not. This would be like the
financial reports being given to only analysts and not to shareholders or the
investing public. The message I get from the arguments against it is that we
investors are stupid and we need the protection of analysts. I, for one, am
tried of their advantages and think it is time that the playing field is leveled
for the individual investor. Some of us have been able to think for ourselves
for a number of years.
Joel Whitener
Author: at Internet
Date: 04/22/2000 5:34 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Proposed Regulation FD: File No. S7-31-99
Sinful ways are aways discovered. Let's have equal disclosure for everyone.
God's watching.
Scott Willis
http://www.sec.gov/rules/0422b02.htm
