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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: "john anderson" at Internet Date: 04/24/2000 9:48 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Dear Jonathan G. Katz, I would like to inform you of my position of why I strongly believe the SEC should approve the Fair Disclosure Act. Individual investors rely on any type of newsource they can get about publicly traded companies. Some information is biased, most information is untimely, and some is flat out untrue. Arguements that support the idea that individual investors can not think for themselves are grossly misleading. Professional money managers argue that they filter out company information and release thier judgement on company issues, playing an undelegated role as an editor of information to the public at large. This type of disclosure descrimintates against the individual investor, and prevents them from having key information that only large financial institutions have. I do not believe professional financial analysts weed out volitile information, but with the media create large overvalueations in some industries, and companies specifically, to control the US economy. To support this look at the large internet technology selloff that had been grossly overvalued for months, and fell sharply 10 months ago. To further support this I personally bought stock in a company "financial analysts" believed to be a horrible investment. 1 year later Advanced Micro Devices (AMD) produces the worlds fastest computer chips, has had spectacular growth, and the industry leader Intel (INTC) can not keep up. One year ago Intel was forcasted as having a dominant hand in the computer chip industry due to market hype and industry analysis of thier past financial statements, not future prospects. Intel now can not fill the orders they have taken, and can not keep up with industry developments. As an investor of four years I saw that the "professional analysts" did not forcast properly, and can not be relied upon by individual investors. Individual investors do not even want analysts opinions, but instead unmitigated, unbiased information about companies that are publicly held. If a company is to be held by the public, it must recieve accurate information. Individual investors rely on the SEC to make investing fair for all. Thank you for your time and I hope the SEC will make decisions to aid individual investors instead of favoring companies to prevent economic growth. Sincerly, John Ryan Anderson University of Tennessee Publicly traded companies should have to disclose any information they do to Corporate Investors as they do individual investors. We can agree that both invest with a profit motive, and that an individual company is no more important than an individual investor. Clai


Author: Albert Braun at Internet Date: 04/24/2000 11:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Hi, I support the move to make corporations disclose their results fully to the public at large as early as they do to the secretive private brokerages and other Wall Street firms. I'm all for the the new SEC proposal on selective disclosure. Best Regards Albert Braun 714 Hampshire Street San Francisco Ca 94110


Author: Renee Chandler-Parsons at Internet Date: 04/24/2000 11:28 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents I strongly urge the termination of the current policy of disclosing important information to Wall street analysts without including the public at large. I strongly support Proposed Regulation FD and consider this regulation vital and representative of the country we live in. We the public make our own financial decisions, and it is imperative that we have the right to the fair disclosure of information by publicly traded companies that we invest in. It is an outrage that the Securities Industry Association assumes we depend on their expertice for guidance, when in fact, the public prefers to ignore their biased opinions. The use of online brokers and educated investors has arrived, and with its presence, the demise of full service brokers.


Author: "Gary A. Clement" at Internet Date: 04/24/2000 9:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Hi, I would like to voice my opinion on the above stated issue. I believe that companies should divulge information publicly if they are going to divulge information at all. If they don't, and they just release it to certain persons on Wall Street, that is just a legal form of insider information selling. This is the information age and everyone has the right to that knowledge, not just the people that can afford lobbyists and bribes. Thank you very much for allowing my voice to be heard. Sincerely, Gary A. Clement Captain, United States Marine Corps


Author: at Internet Date: 04/24/2000 10:41 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I'm for giving the public the same information as the Wall Street Analysts. Joe Cury


Author: "William Dittmann" at Internet Date: 04/24/2000 11:22 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I find it rather ironic that the SIA is telling you that only by letting important news filter through them can market stability can be maintained when it is the institutional investors and programmed selling that cause the severe fluctuations. What I think they are really trying to protect is their ability to help there big investors and mutual funds out of a stock before the rest of the market finds out the bad news. I work for a living, the only knee jerk reaction I can do is to go to the bathroom. the members of the SIA will always react faster than me but atleast this will level the playing field. William Dittmann


Author: djfischer at Internet Date: 04/24/2000 4:52 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Gentlemen: This is to say I am in favor of Proposed Regulation FD: File No. S7-31-99, which, as I understand it, seeks in part to stop the practice whereby firms provide significant company information to selected analysts, but not simultaneously to the general public. I would also dispute certain comments made by The Ad Hoc Working Group on Proposed Regulation FD and the Legal and Compliance Division of the Securities Industry Association ("SIA") on April 6, 2000. The SIA's claim 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" seems to me to be contrary to current trends. When I attended a high school reunion two years ago, many of my former classmates (people are in their late 50's and early 60's) listed their current occupation as managing their investments, and by that they didn't mean they called a brokerage firm from time to time to get their advice and have them place an order. They were actively engaging in research themselves. While not all my classmates are doing this, more than I expected are, and whether or not they all use it, those who do need access to significant information as much as wall street analysts. And note: these are my HIGH SCHOOL classmates. Among my college classmates, this is likely to be even more prevalent. I myself am more likely to trade on-line or through a discount broker using my own research than I am to rely on a full service broker. Should I wish to buy stock in a particular company, I would want all available information to be available to me directly. David J. Fischer New Orleans, LA


Author: "Chris Heinlein" at Internet Date: 04/24/2000 9:28 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Thank you for contributing to the advancement of a truly free, open and democratic marketplace by proposing to require Fair Disclosure of material corporate information. As an investor who believes that simple fairness can only serve to strengthen our national and ultimately our global economy, I strongly support Proposed Regulation FD. You are doing a remarkable job of proving that government has an essential and irreplaceable role in assuring that a "free market" can indeed be free, for the only free market is a morally responsible market. Thank you for moving the US market in that direction. Sincerely, Chris Heinlein President and CEO Heinlein Associates, Inc. Founder of ITC and Synergis Inc.


Author: "Dan Hersey" at Internet Date: 04/24/2000 11:16 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I think what you are trying to do is great! With the advent of online trading a lot more individual investor are getting into the market. With the same data Wall Street is getting it will give us the ability to make those wise investing decisions without the need for the institutional investing (which I'm sure is why the institutions are against this). Keep up the great work!!!!! Dan Hersey Investor


Author: "Ted Y Jones" at Internet Date: 04/24/2000 9:51 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Re above subject; to heck with all the Wall Street lobbysts. Pls. end selective disclosure to Wall Street analysts et al. Thank you, Ted Y Jones, retired.


Author: "J.P. Coleman Park" at Internet Date: 04/24/2000 7:12 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents My name is Kristopher Lange and I wish not to have my rights to be hurt. It's my opinion that Wal-Street and big corporations and banking agencies would rather NOT have the small-investor to have any information. These agencies want us to be scared to think for our selves!!! If this act passes, it will limit us as investors even more. Please do not let this pass. Kristopher Lange 3501 Shiloh Ridge Road Corinth, MS 38834


Author: Jean Mac Donald at Internet Date: 04/24/2000 1:14 AM Normal TO: RULE-COMMENTS at 03SEC Subject: proposed regulation FD:fileno.S7-31-99 ------------------------------- Message Contents Wall Street should not have information that the individual investor does not have access to. We study and make investment choices, as private investors we should have the same information that Wall Street has.


Author: David nordwick at Internet Date: 04/24/2000 1:54 PM Normal TO: RULE-COMMENTS at 03SEC Subject: PROPOSED REGULATION FD: FILE NO. S7-31-99 ------------------------------- Message Contents To whom it may concern, I would like to simple state my support for proposed regulation FD: File NO. S7-31-00. I believe it would help to level the playing field between the individual investor and Wall Street institutions. Sincerely David Nordwick


Author: "Fred Parker" at Internet Date: 04/24/2000 10:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents FULL DISCLOSURE - YES! F. Parker


Author: "Richard D. Perlman; M.D.;M.P.H.;F.A.C.S." at Internet Date: 04/24/2000 9:21 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed reg S7-31-99 ------------------------------- Message Contents Support!Thank you. Richard D. Perlman


Author: William & BlendaPierce at Internet Date: 04/24/2000 7:26 PM Normal TO: RULE-COMMENTS at 03SEC Subject: file s7-31-99 ------------------------------- Message Contents these are public traded company's we are the public to withold information from any one makes this a one sided game and reminds me of Hitler


Author: "Feng Qian" at Internet Date: 04/24/2000 11:36 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents As an individual investor I would like to see information disclosed to all...not just the big guys.. Everybody deserves the same information. Feng Qian


Author: "Stephen Schneider" at Internet Date: 04/24/2000 10:50 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear SEC, I am aghast that it might be considered acceptable to permit investment house analysts to analyze and interpret security filings ahead of individual investors. The collective record of investment house analyst reporting is abysmal, and the evidence overwhelmingly suggests that analysts act in the interest of their firms, rather than in the interest of current or prospective shareholders. Thus to allow analysts special privilege to filings, so as to "help" the individual investor better understand what a company reports, does not corroborate with what the media reports, and what any savvy individual investor knows, about how investment analysts truly operate. That the individual investor somehow benefits from selective corporate disclosure to investment house analysts is a terribly misguided notion which insults the intelligence of any thoughtful individual investor. Such disclosure protects investment houses by serving to perpetuate a dependence by clients on the analysts received disclosures. Thus the investment house, and not the individual investor, is best served. Sincerely, Stephen D. Schneider Individual Investor


Author: "Rajen J. Shah" at Internet Date: 04/24/2000 10:52 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am writing to let you know that I am in full support of the action to force companies to disclose the information that they give to analysts to all the public so that it puts everyone on an even keel. I for one don't like the idea of analysts and brokerages being privy to information that should be public and accessible to everyone. It leads to abuse of power and forces the average person to shell out money for the privilege of having that information. I also don't believe that analysts necessarily make markets less volatile. On the contrary, with the internet business, there is considerably more volatility because the analysts don't have much of a clue as to how to value internet companies. I think the average person, such as myself, can do as good a job, if not better, than what I have seen lately from the analysts. Thank you. Rajen Shah A Moteley "Fool"


Author: "andy spix" at Internet Date: 04/24/2000 10:47 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents The free trade of information is a foundation for true democracy. To treat a small section of a public marketplace with exclusive rights for no reason save tradition is paying homage to a feudal society harkening back to days of barbarism. End Selective Disclosure.


Author: "Steven D. Splinter" at Internet Date: 04/24/2000 10:30 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am writing in regard to the proposed regulation requiring public disclosure of corporate information currently given only to select analysts. I stronly support this regulation, and, contrary to some opinions I have read, believe that it would decrease market volatility, as the "wisdom" of a few select analysts would no longer be the only voice on such matters. Thank you for your attention, Steven Splinter


Author: Charles and Margaret Utt at Internet Date: 04/24/2000 11:15 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation FD File No. S7-31-99 change ------------------------------- Message Contents The proposed rule change is welcomed by individual investors like us. I don't know why a broker should have advantages and preferences to the information available to him. Please continue with plans to change the rules as proposed. Individual investors deserve to be able to have the same access to information as anyone. Thank you for taking the time to read this. Charles and Margaret Utt


Author: "Julieann Willes" at Internet Date: 04/24/2000 11:58 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe it is important in this day and age that all information be dissimanated equally to the everyone. The world is changing and with the internet so has investing. The SEC needs to get with the NEW program and realize that people are more involved than the "used" to be, and this information should not be saved for a select few. Please take this into consideration. Thank you. Julieann Willes

http://www.sec.gov/rules/0424b07.htm


Modified:05/12/2000