Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: kamar aulakh at Internet
Date: 04/25/2000 3:49 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Change the rules that currently allow companies to give important
information to Wall Street analysts without simultaneously giving the news
to the public at large.
Kamar Aulakh
Author: at Internet
Date: 04/25/2000 12:37 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File no. S7-31-99
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Re: Proposed Regulation FD: File No. S7-31-99
I support regulation to "level the playing field" in regard to disclosure.
Janeen Bailey
Author: "Ken Blaese" at Internet
Date: 04/25/2000 12:43 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File #S7-31-99 (Corrected Letter)
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To * pass this Regulation described above, would to say the least, take the
"Individual Investor" and place that investor at a definete disadvantage. If
this is the intention, then it will do just that. It was and should always be
the role of any government institution to work to the benefit of the individual
so that he/she can always have an equal footing in any endeavor he/she
undertakes, especially in rules, regulations, and or laws passed by the
institutions of government, which I was taught, "Of the people, By the people,
and "For the people ! !
When those rules, regulations and/or laws are passed and they favor any "Special
Interest Groups" the "People" get shut out of a fair opportunity to compete or
work on an even or level field of play.
I would implore the Securities & Exchange Commission to keep the "People" in the
equation of fair play and an even field of play.
Thank you for your time and consideration.
Repectfully,
Ken Blaese
*Note: The word "not" should have been included in the sentence, and was left
out by error. ! !
Author: "Boeke; Mark A. CPT" at Internet
Date: 04/25/2000 7:18 PM
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Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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CLASSIFICATION: UNCLASSIFIED
Gentlemen of the SEC,
Make the empowering decision for today's do it yourself investor. We
require and demand full disclosure. Push aside the legislative opposition
being manifested by Wall Street. Thanks for your attention.
Mark
CPT Mark A. Boeke
Battalion SIGO, 6-37 FA(+)
DSN 732-5586 CEL 018-852-2996
An Army that is inflexible will not conquer; A tree that is inflexible will
snap.
-Tao Te Ching
Classification: UNCLASSIFIED
Author: at Internet
Date: 04/25/2000 12:41 AM
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TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD:File No. S7-31-99
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Considering that the market is now being driven by individual investors it's
time they be given the respect they deserve by receiving the same information
and at the same time as the Wall Street Analysts.
Carol Bogaty
Author: bobmar99 at Internet
Date: 04/25/2000 7:11 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support proposed regulation FD: File No. S7-31-99. Company
disclosures should not be selective but be made available to the
investing public.
Robert Cannon
2420 NE 48 Court
Lighthouse Point, FL 33064
PH. 954 360 2833
Author: at Internet
Date: 04/25/2000 9:44 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I do not agree with the filing, dated April 6, 2000, by The Ad Hoc Working
Group on Proposed Regulation FD and the Legal and Compliance Division of the
Securities Industry Association ("SIA"), which posits that individual investors
should not be privy to the same information to which analysts are. The argument
stated therein is deeply flawed, and goes against a founding principle of the
United States, namely, democracy.
Shannon Casey
Perot Systems Corporation
Author: Ed at Internet
Date: 04/25/2000 12:32 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Of course the playing field should be level. To allow selective
disclosure is to create a kind of insider trading for the selected few.
Again the rich get richer at the expense of the little guy.
Ed Cassese,
Owner of Supreme Electric a private company. Also a frequent trader.
Author: "Guillaume Comeau" at Internet
Date: 04/25/2000 1:51 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I totally oppose the principle of selective disclosure and I support the
SEC proposal.
Regards,
Guillaume Comeau
Zucotto Systems.
Author: at Internet
Date: 04/25/2000 5:26 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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I am a small investor in the stock markets and feel I have just as much right
to have company information available to me as analyst, and at the same time.
I buy stocks which I have researched well and during the period I own them,
check for company news quite often.
All I ask for is a level playing field.
Thanks,
J. S. Conoly
9526 SW 67th Drive
Gainesville,
FL 32608
Author: mikeduerr at Internet
Date: 04/25/2000 1:49 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I feel that selective disclosure is unfair, and is not
equal protection under the law as required of the
US government by our constitution.
Any law that gives certain investors access to information, but
allows it to be withheld from others, must not be allowed!
--
Looking at the overall health of the market for all investors,
it would seem to me that access to MORE information by small
investors on the same basis as institutional investors and
analysts will make the market MORE STABLE as individuals have
more information on which they can base rational action, as
opposed to throwing darts and attempting to ride market
momentum. In short, you proposal will encourage volatility and
speculation on the part of individual investors, with result
that will likely encourage volatility like we have seen in
recent weeks.
Michael Duerr
644 North Williams Drive
Palatine, Illinois 60067
Author: "Paul Fabbroni" at Internet
Date: 04/25/2000 8:03 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Re :Proposed Regulation FD: File No. S7-31-99"
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Dear Sir,
I think the SEC is entirely misguided in its attitude to private investors, and
as to the importance of Wall Street analysts.
1- I for one DO pore over company reports and financials.
2- Wall Street analysts do NOT serve a useful function in my opinion, save as
opinion leaders. Their inaccuracies in analysis are frequent and - once again,
in my opinion - highly biassed. They seem to act in the interests of the
companies they follow (witness the complete dearth of sell reccomendations in a
market overpriced by any historical standards) and - perhaps - more nefariously
in the interests of their more well-off institutional investors who perhaps (?)
are prewarned of changes in the perceptions of companies by Wall Street.
It may well be dangerous for private investors to pay too much attention to the
market. However, the alternative seems more dangerous - how many 'experts'
foresaw the various financial panics we are all familiar with? To rely on their
'unbiassed', 'astute' judgements can be very dangerous.
However, as I said above, as opinion leaders they are very valuable. An analyst
upgrade (or a series of them) do seem to drive short term price movements, and
are worth following for that purpose. Also, some analysts - Milunovich at
Merrill Lynch - do seem to write well balanced and informative company briefs.
However, please note that no one - not even Milunovich - is addressing the
central problem of how companies with PEs over 100 (even very profitable
companies like EMC and Cisco Systems) can EVER earn enough money to provide a
dividend cash flow equal to the prices now paid for those comapnies stocks. It
seems to me that objective analysts ought to address this issue.
In contrast, fund managers (like Soros and Buffett) have been noting the
overvalued conditions on Wall Street particularly amon technology stocks.
If the SEC really wants to do some good, focus on the rosy expectations dreamt
up for the 'new economy' and look at the ways this can be deeply misleading.
Yours sincerely,
Paul S. Fabbroni,
US Citizen living abroad
Author: farchmir@milwaukee.tec.wi.us at Internet
Date: 04/25/2000 12:24 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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The SEC's proposed Proposed Regulation FD: File No. S7-31-99 is an
excellent proposal which has been long overdue. It would go a long way
toward eliminating the 'selective disclosure' of important information --
information that should be available to the individual investor as readily
and in as timely a fashion as it is available to selected securities
analysts and/or institutional investors.
The present system excludes members of the public and the media from
obtaining essential information in a timely manner in a manner. The present
system gives a temporal advantage to selected industry analysts and certain
institutional investors that is not unlike the advantage held by inside
traders; therefor, the current situation should be remedied by
implementation of the proposed regulation.
I have read the comments recently submitted by representatives of the
Securities Industry Association, and have found them to be blatantly and
tgransparently self-serving. The aims of the SIA are precisely the
opposite of those intended by the proposed regulation. The SIA's
objections to the proposed regulation are aimed at preserving certain
analysts' and investor's monopoly on timely information and to prevent the
public from obtaining information from direct sources in a way that
effectively restrains free trade in the type of information that is
necessary to all investors by restricting the flow of such information to a
limited number of outlets.
In summary, I am fully in favor of implementaion of Proposed Regulation FD:
File No. S7-31-99.
Thank you for your attention.
Randall Farchmin
Menomomee Falls, WI
Author: Trevor Ford at Internet
Date: 04/25/2000 7:49 AM
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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:
As a non affiliated investor, I applaud the SEC's current drive to open
market information to me and to all my fellow investors.
Like many of my kind, I have made a considerable effort to be able to
understand company financials, annual reports and prospectuses. I
prefer to make and stand by my own decisions in buying and selling
equities.
BUT, I need, no, demand, full disclosure. This MUST NOT be restricted
to the members of the Securities Investment Association.
Please help us level the playing field.
Thank you
Trevor D. Ford
Author: Patrick Frisby at Internet
Date: 04/25/2000 12:30 AM
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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 for all. In fact I demand it. The little guy
has the right to this information.
Author: at Internet
Date: 04/25/2000 1:48 AM
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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:
Abolish selective disclosure. There needs to be a level playing field.
Selective disclosure is a form of discrimination. The rules need to be the
same for EVERY investor.
Sincerely,
Jeffrey C. Gagliano
Author: Tom Greene & Anita Dugat-Greene at Internet
Date: 04/25/2000 5:25 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am an individual investor. I fully support the new regulations
against selective disclosure of financial information by publicly held
companies. Thank you.
Thomas Greene
Author: at Internet
Date: 04/25/2000 12:23 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Purposed Regulation FD: File No. S7-31-99
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I am against selective disclosure to Wall Street analysts. Important
information about a publicly-traded company should be made simultaneously to
both the publick and Wall Street analysts. This is a moral issue that should
be corrected immediately, if not sooner! It is NOT right that a Wall Street
trading firm should be granted the right to buy stock in a company that "they"
have been "briefed" by, only to "pump and dump" that companies stock for a
profit.
The playing field needs to be leveled.
Kevin Hardcastle
twaflyboy1@aol.com
Author: "Hotchkin; Michael" at Internet
Date: 04/25/2000 1:16 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear SEC representative:
I strongly object to the routine disclosure of information provided to
investment analysts prior to general release to the investing public. This
unfairly biases market performance against individual investors.
Specifically, efficient market performance is only possible when all
investors have equal capacity to information resources. Providing
information to analysts prior to the general public precludes market
efficiency by allowing institutions the subtle ability of preparing for
potential market conditions. All investors should have equal access to
company information at appropriate times.
Further, I would argue that selective disclosure is largely equivalent to
insider trading. Those institutions receiving the selectively disclosed
information have an opportunity to profit from that information, at the
expense of the majority of investors who do not receive the selective
disclosure.
I endorse the proposed rule.
Cordially,
Michael Hotchkin
Author: at Internet
Date: 04/25/2000 12:50 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Mr. Levitt:
I am totally in favor of this regulation which I believe begins to "level the
playing field" for individual investors such as me.
Thomas Hsia
( an individual investor )
Author: Charlie Jameson at Internet
Date: 04/25/2000 12:42 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File #S7-31-99
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In an "Information Economy", selective disclosure seems to be a bit like
cheating. Sorta like knowing which horse will win the race, before the
bell sounds. Level playing fields allow everyone the same opportunity. I
support equal access to
information.
sincerely, Charlie
Jameson
Author: Stuart Kajfas at Internet
Date: 04/25/2000 6:31 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I wish to go on record as opposing selective disclosure.
Stuart M. Kajfas
Author: at Internet
Date: 04/25/2000 2:48 AM
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TO: RULE-COMMENTS at 03SEC
Subject: FD:File No. S7-31-99
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I am in favor of the SEC changing the rules so that the public at large
will be given the important information that is given to Wall Street analysts.
I feel the individual investor deserves to receive this news at the same
time as the analysts, and that they be given the information directly from
the companies involved, not from an analysts that might have conflicting
interest.
Investors need all of the facts in a timely manor in order to make their
investment decisions.
Thank you for your consideration of this matter.
Betty Mae Killeen, Independent investor
Author: "NFKNOLLMANN" at Internet
Date: 04/25/2000 5:03 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation S7-31-99
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Dear Sir;
i think everyone should have the same access to information and at the same
time. The little guy is important as well as the big boy.
I am asmall business owner (lakeland Estates Mobile Home Park) and I am
tired of the little guy being kicked around and being treated as a second class
citizen.
Norbert Knollmann
nfknollmann@msn.com
Author: "Bryan Lee" at Internet
Date: 04/25/2000 2:23 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: S7-31-99
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I support full disclosure of all information related to public companies to the
general public.
Bryan Lee
Rivendell Records
Author: at Internet
Date: 04/25/2000 10:39 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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We urge for stricter rules to improve FD.
The Raven Institute Foundation:
drs C.A.M. Leijten o.s.m.c.
drs R.E. Sergo o.s.m.c.
L.A. Bouts o.s.m.c.
Author: at Internet
Date: 04/25/2000 2:16 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: No. S7-31-99
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Edited message: Original message: Tuesday, April 25, 2000, 2:36:22 A.M. The
proposed rule change is very important to me; an individual investor. I do my
own research and I rely on information developed by "The Motley Fool" and
research done by friends who have similar goals and good research skills.
Equal access to information would make an enormous difference in my ability
to make reasoned decisions. Today, under no circumstances would I trust
information provided by an analyst: I cannot be sure the comments are
unbiased. Surely an intelligent analyst would welcome a "level playing
field". I would gladly pay for analysis I could trust; research is tedious
and appallingly time consuming. With everyone receiving the same information,
at the same time, that person who could provide accurate, truthful, unbiased
analysis would be of great benefit to those millions of us who are actively
engaged in managing our own portfolios.
Sincerely,
Nancy Anne Manno
Author: at Internet
Date: 04/25/2000 3:39 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD : File No.S7-31-99
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We need new fair disclosure rules. Thanks, Dewayne Maxwell dmax93550@aol.com
Author: Peter Mescher at Internet
Date: 04/25/2000 12:03 AM
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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,
The Securities Industry Association has filed several public comments
opposing the enaction of Proposed Regulation FD. It is my impression
that they are seeking to preserve the current state of affairs where
investment analysts have access to information from issuers that is
unavailable to individual investors at the same time. This analysis of
this information, as you are well aware, is then disclosed to the paying
clients of said analysts before said information is available to the
general investing public.
On 4/6/2000, the Securities Industry Association filed a comprehensive
comment opposing the proposed regulation on several fronts. While I do
not have extensive knowledge of SEC regulations, I disagree with many of
the points the SIA is presenting.
The SIA states "We believe that many conscientious issuers will seek to
avoid the problems created by Regulation FD by eliminating meetings with
individual analysts and small groups of analysts, becoming more
circumspect in what they say at open meetings and eliminating the
current practice of frequent telephone conversations with analysts. All
of these steps will result in less information to investors." This is a
pointless objection.
The elimination of meetings with individual analysts and small groups of
analysts where the information is not promptly disclosed to the the
public seems to be precisely one of the major objectives of the proposed
regulation. While the elimination of these non-public meetings could
reduce the flow of investment analysis available only to those investors
able to afford the services of the analysts, the information available
to the common investing public would certainly not decrease, as they do
not have access to this information now.
The SIA goes on to say the the prospect "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."
While I am not suggesting that all individual investors would suddenly
undertake unprecedented levels of research before making investment
decisions, the individual investors should be able to make these
decisions for themselves. Under the status quo, they simply do not have
access to this privledged information.
They then go on to wax eloquently about the courageous analysts braving
the dangers of corporate spin and outsmarting the wits of other, less
capable, analysts with their keen powers of intuition and ability "to
watch for changes in choice of words or tone of voice." They claim that
the proposed regulation somehow results in the undermining of some
unspecified "advantages" that the current system of information provided
only to analysts provides. They seem to suggest that leveling the
playing field will somehow cause the analysts to have less incentive to
engage in their keen analysis of the information available to them.
This very notion is patently ridiculous. They will still be able to
analyze one company versus it's competitors and attempt to produce
conclusions of a companie's prospects based on that information. They
will still be able to look for trends in a company's business. The
difference under the proposed regulations will be that the individual
investors that cannot afford access to their exclusive reports and
inside analysis will now be able to try to make their own analyses.
While the ability of investors to make more informed decisions might
occur to the financial detriment of the analysts, that is certianly no
reason to avoid implementing the proposed regulation.
While the SIA has many objections to specific language in the proposed
regulation, I am not qualified to evaluate these statements since doing
so would require extensive knowledge of current securities regulations
which I do not posess.
In conclusion, I agree with the principle and sprit of the proposed
regulation FD, and encourage that it be adopted in some form.
Peter Mescher
Raleigh, NC
Author: at Internet
Date: 04/25/2000 2:03 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Let us all have the data. Not all of us need protection from ourselves
Wayne Mitcheltree
Author: at Internet
Date: 04/25/2000 1:18 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Selective disclosure is immoral and should be illegal. It only serves to
perpetuate a good-old-boy system that makes you pay them because they have
the information. They should be paid only if they are better at interpreting
and understanding, and the marketplace is the best place to decide that.
Selective disclosure supports sanctioned insider trading and prewarning for a
select few. General disclosure still lets me let my broker interpret for me
if I wish to. Many investors are better educated and capable of
understanding then the brokers you may force them to work thru.
You should be requiring electronic release of information for general access,
not playing to the insiders club that makes a living only because they get
first peek at the information.
Donald H Morris
805-495-9669
morrisdh@aol.com
267 Scarborough St.
Thousand Oaks CA 91361
Author: Richard Nist <"nist-md "@ak.net> at Internet
Date: 04/25/2000 12:02 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:F#S7-31-99
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Sir:
I oppose any regulation that allows company information to be
selectively given to Wall Street analysts and not all investors in that
company simultaneously.
If I had important medical information about you should regulations
be passed that I could share that information with your insurance
company and not you?
Richard T. Nist, M.D.
Author: "matt noell" at Internet
Date: 04/25/2000 2:47 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Concerning the proposed rule, it is my opinion that ALL investors should
have access to company information as it is released. To argue that
investors can't understand information, or that analysts' access to
information ahead of it's release to the public enhances the markets is
absurd. A level playing field for ALL investors will drive the markets to
new heights.
Matt Noell
Author: "Bernie Odoy" at Internet
Date: 04/25/2000 5:56 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Full disclosure is a must for all investors and the power of information can not
be given to a select few
Bernie Odoy
Author: "Dwayne Pascal" at Internet
Date: 04/25/2000 10:30 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the proposed regulation change which would level the
playing field for individual investors.
Dwayne Pascal
NOTE: This message is my own opinion only and does not represent
an opinion or position by my employer in any way, shape or form.
Author: at Internet
Date: 04/25/2000 2:59 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Hi,
How can anyone claim that the NYSE, NASDAQ, AMEX, etc., are the markets to
trade because of their disclosure rules when they all allow companies to
release selected information to privileged individuals and allow them to trade
on the information prior to its release to the public? Would those making the
rules feel nearly as comfortable with these rules if the situation was
reversed? I doubt it!
Please level the playing field and ensure information about publicly traded
companies is released at a time and in such a manner that it is available at
the same moment to all interested parties.
David A. Pasero
Author: at Internet
Date: 04/25/2000 1:33 AM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Please,change the rules that currently allow companies to give important
information to Wall Street analysts without simultaneously giving the news to
the public at large. While Wall Street is spending big and lobbying hard to
keep the current system of selective disclosure in place.
Stephanie Ponn
605 South Wisner
Jackson, MI 49203
Author: at Internet
Date: 04/25/2000 12:55 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am opposed to having selective information given to analysts. This is
inherently a conflict of interest and unfair to the public which deserves to
have the same information that the analyst does.
Dennis Ryan
Author: at Internet
Date: 04/25/2000 12:30 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please allow full disclosure to all investors by eliminating the current
rules that allow analysts to receive information that is not distributed to
the general public. This borders on the ethics that prohibit insider
trading. The public should be allowed the same opportunities as the Wall
Street analysts.
Thank you
Travis Sargent
Author: at Internet
Date: 04/25/2000 12:07 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD.File No.S7-31-99
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I think it is about Time for all shareholders to get the Company information
at the same time. The Brokers should not have a monopoly on advanced
information.
Frances Scott Www.Thoranite @ AOL. com
Author: at Internet
Date: 04/25/2000 1:25 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD:File No. S7-31-99
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The existing system has always been clearly unfair....the chosen ones can act
upon the information before it is known by the general investing public. Any
action you take to stop the existing practice and force wider distribution of
ALL corporate statements will be an improvement. Opposition to wider, timely
distribution of information can only come from those who have a beneficial
financial interest in the exiting system of selective disclosure.
William W Taylor
SOBill@aol.com
Author: "Jim E Thomas" at Internet
Date: 04/25/2000 6:52 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed reg FD: file no. S7-31-99
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Level the field and improve the market efficiency that is what it is all about.
Jim
Author: at Internet
Date: 04/25/2000 5:53 AM
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TO: RULE-COMMENTS at 03SEC
Subject: FD: File No. S7-31-99
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I am a member of the public at large & I don't like a selective disclosure
policy.
Kathleen Trossbach
Author: "Diego Vargas" at Internet
Date: 04/25/2000 7:49 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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My name is Diego Vargas. An accounting student and candidate of a master in
CIS at Bentley College, Mass.
What's up with that discrimination to small investors? You are supposed to
protect ALL of us, not only a small part!!!
You want us to hold the bag for all the losses in the market. Let's share
profits and losses!
The financial information from companies should be given to us at the same
time. What is the Internet for?
Diego Vargas
Author: at Internet
Date: 04/25/2000 12:09 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Companies should release their information to the general public as well as
the market analystst at the same time. I oppose the above proposed
regulation.
Sincerely yours,
Phillip M. Walker, MD
Author: at Internet
Date: 04/25/2000 12:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I wish to let the SEC know that I support the proposed Fair Disclosure
rule.
Thank you.
Dr. Joseph A. Weinstock
Author: at Internet
Date: 04/25/2000 1:18 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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INFORMATION IS POWER
The power and versatility of the Internet allows a consumer to research
products or services prior to selection, thus enabling a better decision. For
example, prior to purchasing a car, a potential buyer can research:
reliability, average cost of repairs, safety record, insurance costs, and how
well a particular model holds its value over time.
If public access to this type of information was denied by people in the
business of selling cars, it would allow those same people to control and
manipulate information for their own advantage.
This principle is equally valid when it pertains to financial information
regarding companies that are publicly traded. To allow selective disclosure
of such vital information is to distort any semblance of fairness to all
shareholders.
The current system is rife with abuses. It rewards those in the 'inner
circle' and treats those outside to unfair treatment. This is highly similar
to Insider Trading, where people with access to confidential information use
it for their own financial advantage. Please enact the proposed regulation,
and give all shareholders a level playing field.
Nancy Weiss
Tucson, Arizona
Author: at Internet
Date: 04/25/2000 12:08 AM
Normal
TO: RULE-COMMENTS at 03SEC
CC: YYYING1@aol.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern:
I have reviewed the proposed Rule as well as the SIA's response thereto.
Under the principles behind security regulation in general and the goals of
the SEC in particular, the Rule should be adopted.
First, I recognize that most individual investors receive news and
opinions from industry analysts. It is important to note that those opinions
are almost always moderated through the lens of some professional in various
forms, ranging from a stockbroker to an investment advisor to a newsletter
writer. The investment professional is supposed to separate the valuable gems
from the cheerleading noise. But the coded language underlying the facially
optimistic reports endemic to the industry makes analyzing the analysts a
rococo art.
One obvious example in the last year: The reaffirmation of a long-term
buy recommendation on IBM. The report suggested that Y2K would impact the
quarter but would not be a significant development. When share prices
declined to 90, the analyst criticized his sales force at Merrill Lynch for
failing to sense that the essay really meant "short-term sell" under the
language of "long-term buy." Thus, even if the analyst is extracting deep
information from "an upturned eyebrow" or a "tone of voice," that data is
communicated (if at all) to the sales force and retail investors through a
weird code.
Second, the SIA's response suggests that the new regulation would give
an advantage to those "watching the screen." Well, yes. The whole nature of
investing should be that those most able to USE information can reap an
honest profit. At present, the investment analysis (and investment banking)
community gets an edge not based on its talent but on its privilege. If they
are able to use information better than others, then they do add value to
their product. But if they grasp vital information simply because they are
"on the inside" (i.e., through the privilege of access rather than the merit
of thought), then they are asking the SEC to bless a noxious monopoly.
By way of example, we should all remember the market convulsion caused
last February when a PaineWebber analyst discovered that Compaq's sales were
coming in under estimates. Thank goodness that event occurred after hours
and during a q-and-a session attended by a number of people. Had the
discovery come to light at, say, 11:15 a.m., there would have been massive
market dislocations and inevitably massive regulatory problems in the
aftermath.
Third, the SIA's response credits its members with gleaning negative
information from upturned eyebrows and tones of voice. But, like the defense
attorneys looking for innocent accused to defend, I have to ask where these
negative reports are. I can't find enough sell reports from the whole
industry to fill a single notebook. In the past year over 53% of stocks are
down year-over-year, yet these aces can't seem to find any.
In short, the securities laws aim for transparency and reasonable
disclosure. The current regime is not transparent EVEN TO ITS OWN
PRACTITIONERS. It is less than honest with itself: it shows by experience
cannot pronounce any issues ripe to sell (for fear of retaliation by
management) and it admits by its own argument that it cannot add value by
sheer thought; it needs inside information. In short, the disclosure
requirements should catch up to the 21st century, and the Rule is, on
balance, a reasonable first step.
Thank you for your time and kind attention, and if you have any
questions, please do not hesitate to contact me.
Charles L. Weissing, Esq.
YYYING1@aol.com
http://www.sec.gov/rules/0425b01.htm
