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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: Bruce Allard at Internet Date: 04/25/2000 1:52 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents In the interests of individual investors everywhere, please stop this obscenity called selective disclosure. It is immoral, indecent and not fair. - Bruce Allard


Author: "Jan Barak" at Internet Date: 04/25/2000 11:16 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe that there should be as equal access to company information by the general public as there is to "stock market analysts." It is unfair to have companies release info to just the analysts who then "interpret" it for John Q. Public. We are intelligent enough to do our own interpretations. Janet S. Barak


Author: Duane Bartholomew at Internet Date: 04/25/2000 7:27 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To whom it may concern: I favor the Proposed Regulation FD, which would require, among other things, that companies 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. It is a commonsense rule that should already have been implemented. I dislike selective disclosure to an elite group of analysts, don't feel that such analysts contribute significantly to my understanding or perception of the market, and believe that publicly traded companies should make information relevant to owners or potential owners of a particular companies stock available to all of the public. The position of analysts against such rule is self-serving and their comments are demeaning to me and others who conduct their own analyses of a companies data and purchase stock through a discount broker without the assistance of analysts opinion. Thank you for the opportunity to comment. Sincerely yours, Duane P. Bartholomew 518 Kaumakani St. Honolulu, HI 96825 808-395-3317 ---------------------------------------------------- Duane P. Bartholomew, Agronomist emeritus, Univ. of Hawaii 518 Kaumakani St., Honolulu, HI 96825 (E-Mail: duaneb@hawaii.edu) Pineapple Web Page at


Author: at Internet Date: 04/25/2000 12:58 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents As an individual investor, it is frustrating to see stock prices effected by announcements given in private to large holders of the stock or other analysts. The government should not protect big money at the expense of the individual investor. All investors should be treated equally and all announcements should be made to all investors at the same time. Please pass this proposed regulation. Arthur G. Bingman, Attorney-at-law


Author: Victor Bishop at Internet Date: 04/25/2000 12:05 PM Normal TO: RULE-COMMENTS at 03SEC Subject: S7-31-99 ------------------------------- Message Contents I am writing to lend my voice in favor of ending the current system of selective disclosure. Let the people be heard!


Author: MIRIAM BLATT at Internet Date: 04/25/2000 11:05 AM Normal TO: RULE-COMMENTS at 03SEC TO: mblatt@Sun.COM at Internet Subject: Proposed Regulation FD: File No S7-31-99 ------------------------------- Message Contents Hi, I'm writing in support of the proposed regulation FD: File No S7-31-99 because eliminating selective disclosure adds fairness to the investment marketplace. Please expedite its introduction. Thanks, Miriam Blatt Menlo Park, California


Author: Maynard Brandsma at Internet Date: 04/25/2000 11:48 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents There should be no selective disclosure. All disclosure should be fully public and available to everyone. Thanks for considering my opinion. Maynard G. Brandsma Durango, CO


Author: "Ross Budden" at Internet Date: 04/25/2000 6:53 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I fully support this proposal for uniform disclosure! Ross Budden 1218 West Dravus Seattle, Washington 98119 President Sturdy~Weld Equipment & Design, Inc.


Author: "john burgess" at Internet Date: 04/25/2000 10:42 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To: SEC Make it fair for everyone!! Please do not let the big boys keep control and dictate to the rest of us!! We are not ignorant idiots and do not want to be treated as such!! This is still America, isn't it!! Let the freedom reign over all, not just a few!! Sincerely, John Burgess


Author: Jim Edgington at Internet Date: 04/25/2000 1:17 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please force all companies to announce there decisions to the public at large and stop selective disclosure. Thank you, Jim Edgington Jim.Edgington@LabOne.Com (913) 577-1335


Author: "John Fleming" <1fleming@bellsouth.net> at Internet Date: 04/25/2000 12:32 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am an individual investor and I would like to see information disclosed to all...not just a select few. Therefore mark me as for the proposed rule change noted above. Thank you for the opportunity to comment. Tracy Fleming


Author: Colin Foster at Internet Date: 04/25/2000 1:13 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Re: Proposed Regulation FD: File No. S7-31-99 Mr. Katz, I writing to advise you of my opposition to selective-discosclosure between public corporations and financial analysts. I am sure you are well aware of all the arguments why one would be opposed to this practice so I am going to spare you a regurgitation of all those same facts. I simply wanted to add my voice to the group who would like to see this practice changed. Sincerely, Colin Foster -- Cognizant Consulting Inc. 406-1055 Bay Street Toronto, Ontario, M5S 3A3


Author: Skate Dancer at Internet Date: 04/25/2000 1:59 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I forgot to put the header in the subject line. ----- Original Message ----- From: Skate Dancer To: rule-comments@sec.gov Sent: Tuesday, April 25, 2000 1:50 PM Subject: Disclosure Information To the SEC: I believe that the general public should have the same equal access to disclosure information from companies as the Wall Street analysts. That is not to say that there is no role for the Street analysts or that their roles are to dramatically change. They can still render their opinions based on the facts that are presented to them. I feel that the general public should be given the option of deciding whether or not they want to buy securities based on full disclosure and their own logical conclusions or that of someone else. Aisha Garner Shareholder


Author: "Gary W. Gerfen" at Internet Date: 04/25/2000 9:17 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Jonathan G. Katz, Secretary, Securities and Exchange Commission, 450 Fifth Street, N.W., Stop 6-9, Washington, D.C. 20549. Re: Proposed Regulation FD - File No. S7-31-99 Dear Mr. Katz: I write in support of proposed regulation "FD." The degree to which individual investors impact, and in our aggregate constitute, the market, has and will continue to increase as more people take control of their investments in individual stocks and varied retirement plans. In this regard we do not act on the advice or counsel of "analysts." We are performing analyses on our own behalf, and for this we require access to the raw information of commerce. In order to participate on a level playing field we require, and deserve, access to the same information at the same time as other market participants. The spectre of this level playing field terrifies and threatens the livelihood of for-hire analysts. If one is the sole conduit of certain (non-mandated for release) information then one will disseminate it as a work product, for pay, and on a schedule and in a forum that suits one's own needs, not those of other market participants. Mr. Katz, I strongly encourage you to resist the efforts of entrenched interests to hold back the forces of progress which have helped make the boom of the last decade possible. Sincerely, Gary W. Gerfen gerfen@icnt.net


Author: "Gray; Robert C" at Internet Date: 04/25/2000 12:39 PM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I believe your proposed rule to force a public company to release all relevant information to the public instead of just the selected "analysts" is a good idea. Companies now appear to release possibly damaging information to "their preferred" analysts first in the hopes that these analysts will "tone down" or "spin" the bad news into a more palatable story. This also offers the analysts the time to warn their customers out of a particular stock before the general public has the opportunity to actually see and interpret the information on their own. The same goes for good news. If the selected analyst receives the information ahead of the general public he can position his customers to profit from the potential rise of a stock when the individual long-term investor gets the information and acts on it. Please consider whether the present system is actually more or less likely to cause volatility. I believe the analyst getting advanced notice only allows them the advantage in cashing in on the volatile market. Thank You, Robert Gray Robert Gray - Q&PI - NDI inspection 6-0005 pager 5-2281 Your mouse has moved. Windows must be restarted for the change to take effect. Reboot now? [ OK ] ANONYMOUS


Author: steven gray at Internet Date: 04/25/2000 11:15 AM Normal TO: RULE-COMMENTS at 03SEC Subject: proposed regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear SEC: I am in favor in the regulation which gives disclosure of information to all parties equally at the same time. Since many of us cannot afford to pay the brokerage fees for information, it seems very unfair to basically allow analysts to "pay" for selective disclosure of financial information which puts many of us at a disadvantage. Many analysts add nothing to research reports except a rehash of what was disclosed to them. And then they charge the public for the information. Forcing companies to disclose information to all shareholders equally would make all parties more honest as well. Again, I will state that I am strongly in favor of making all disclosure public to shareholders at the same time and I am against any disclosure to " analysts" selectively that does not allow us access at the same time to information that would affect stock valuation. Steven Gray Salt Lake City, Utah 801-272-3503


Author: Bill Grimwood at Internet Date: 04/25/2000 1:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am in favor of the proposed rule regarding the fair disclosure of information by publicly traded companies to the public. I feel individual investors are intelligent enough to make their own decisions about the value of securities and do not need Wall Street's analysts to hear and interpret important information first. Bill Grimwood Individual Investor


Author: "edward haberek jr." at Internet Date: 04/25/2000 2:01 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-31-99 ------------------------------- Message Contents I feel there should be full disclosure to the public. Thank you. Edward Haberek


Author: Sandy Hamilton at Internet Date: 04/25/2000 10:47 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear SEC, If there really is such a thing as a level playing field, then the rules must change. If these guys on Wall St. are so much smarter than the rest of us, they should not worry about us getting information at the same time they do. This rules about insider trading always seemed to me to be about people gaining an unfair advantage when it came to buying and selling of securities. Well, this situation doesn't appear all that different to me. It's time to fix an antiquated notion and create truly open markets. Thank you for your consideration, Alexander Hamilton


Author: "Steve & Donna" at Internet Date: 04/25/2000 12:06 PM Normal TO: RULE-COMMENTS at 03SEC Subject: FD S7-31-99 Proposed regulation ------------------------------- Message Contents Make the playing field level for all investors, As an individual investor I would like to see information disclosed to all ...not just the big guys.. . We deserve the same information as the big boys get. Steven D. Helm


Author: "Herby; Tim" at Internet Date: 04/25/2000 10:50 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am writing to let it be known that I strongly approve of the sharing of all information about companies that I invest in. I want to be able to look up ALL the facts. This does not mean I will no longer look at analysts for insight into the market. However, I would like to be able to see what information they have to back up their suggestions. Tim Herby Vividence Inc.


Author: at Internet Date: 04/25/2000 1:31 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No S7-31-99 ------------------------------- Message Contents Support fair disclosure. Kathy Hyle


Author: jischy at Internet Date: 04/25/2000 1:23 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I highly recommend that the proposed regulation for fair disclosure be passed as a requirement that all companies give equal disclosure to the public investor, not just to analysts and brokers. Janet E. Ischy


Author: at Internet Date: 04/25/2000 1:32 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed regulation F D: File No. S7-31-99" ------------------------------- Message Contents Sorry, I just wrote against any discrimination aganinst the majority of the people and did not put in the file number. Please think about the majority of the people and that is what it is all about. Sincerely yours, Joan J.Kennedy JodyK2@hotmail.com


Author: "Kinsey; Scott" at Internet Date: 04/25/2000 10:13 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Dear Sirs: I support the proposed new rules for the SEC in the area of Fair Disclosure. I feel that our economy is evolving to one where the individual investor is taking a more active interest in their finances rather than handing it over to an institutional investor. In order to fairly compete with the big institutional investors, the individual investors need to have access to the same information. Thank you for your time. -- Scott Kinsey Simi Valley, CA


Author: "Macrae; Jonathan" at Internet Date: 04/25/2000 1:19 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents To Whom This May Concern, I heartily endorse the proposed regualtion FD. This proposed orderly and fair dissemination of information is long overdue. The present system is set up only for the benefit of Brokers and it is my belief that this creates inefficiency and waste in the system. Please consider this memo a strong vote for regulation FD Sincerely, Jonathan Macrae


Author: "Peter J. Mas" at Internet Date: 04/25/2000 1:43 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Rule: S7-31-99 ------------------------------- Message Contents To Whom It May Concern: I support the SEC's proposed rulemaking for fair disclosure of material information from issuers. This rule should provide for less insider trading and less manipulation of the market value of a given stock. I encourage your agency to approve this rule. Respectfully, Peter J. Mas 7 Sylvan Drive Middletown, CT 06457


Author: "Jim McKinney" at Internet Date: 04/25/2000 2:06 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am all in favor of the proposed regulation. It does not hurt the analysts except where they do have an unfair advantage. Under the current system, the big boys have an unfair advantage. Transparency = Level Playing Field = Longer Term, Better Health of the Markets as it is not only fair, and what this country is all about, but establishes even greater faith in the markets, and encourages longterm perspective as a whole. A good analysts will still be able to provide his or her valuable services and expertise without what is effectively a monopoly on the data (even if it is only in a time-frame sense). I thought it a good analogy when someone compared the current situation to that period in Church History when only a select and powerful few were able to read the Bible (because it was only in Latin). With the translation of the Bible into modern languages, religion itself was not hurt. People still looked to the current hierarchy for guidance, but they were able to SUPPLEMENT their options by reading for themselves. I beleive, in the long run, this helped the Church. Jim McKinney Atlanta, Georgia (404) 373-8116


Author: "Malcolm McWeeney" at Internet Date: 04/25/2000 11:14 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Full disclosure please, to all. Malcolm C. McWeeney


Author: at Internet Date: 04/25/2000 1:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Investors deserve a fair market, period. Morally and legally and if not now through this venue, we will get it eventually! Please do the right thing! Sincerely, Shawn Meehan From the Desk of: Shawn Meehan 1977 Woodglen Ln. #3 Vacaville, CA 95687-6145 ----------------------------------------------------- Home Phone: 707-446-7107 Office (www.VitalStocks.com): 707-446-8225 email: shawnm9326@aol.com


Author: ann orlov at Internet Date: 04/25/2000 2:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File S7-31-99 ------------------------------- Message Contents I support full disclosure -- there is no excuse for a few to have more information than the rest. Isn't that a form of insider trading which is already illegal. Ann Orlov MDiv, STB PO Box 455 Stowe, VT 05672 1-802-253-7857 phone 1-802-253-7828 fax


Author: "Steve Padgett" at Internet Date: 04/25/2000 2:05 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am for leveling the playing field (banning selective disclosure). Steve Padgett


Author: "Mike Phaup" at Internet Date: 04/25/2000 12:26 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents No more selective disclosure. It is patently unfair to self directed investors. Michael Phaup Real Estate/Insurance 427 Rice Rd Tyler, TX 75703


Author: "Randy Rhea" at Internet Date: 04/25/2000 1:27 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents PLEASE STOP SELECTIVE DISCLOSURE I agree with the Securities and Exchange Commission Chairman Arthur Levitt who said, "The all-too-common practice of selectively disseminating material information is a disservice to investors and undermines the fundamental principle of fairness. This practice leads to potential conflicts of interest for analysts and undermines investor confidence in our markets." Please end this practice. Thank you. Marvin R. Rhea


Author: "o" at Internet Date: 04/25/2000 1:35 PM Normal TO: RULE-COMMENTS at 03SEC Subject: "Proposed Regulation FD: File No. S7-31-99" ------------------------------- Message Contents Please allow general access of information to the public-at-large and put an end to the selective disclosure of information to certain brokers/analysts. Oscar Rizzo


Author: at Internet Date: 04/25/2000 1:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I am in favor of ending selective disclosure of information from publicly traded companies to brokers and analysts. I support the change in regulations. Peter Roche


Author: "Art Scott" at Internet Date: 04/25/2000 1:37 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Fw: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Sorry, I forgot, I am Arthur E. Scott Adjunct Professor of Computer Science Marist College Poughkeepsie, NY 12601 Regards, ArtS ----- Original Message ----- From: Art Scott To: rule-comments@sec.gov Sent: Tuesday, April 25, 2000 1:29 PM Subject: Proposed Regulation FD: File No. S7-31-99 I'm opposed to any idea that a small group of people should get and interpret financial information for me. I can make my own decisions thank you very much. I resent that our government would even consider giving a special group information in advance of the general public. Regards, ArtS


Author: papu shah at Internet Date: 04/25/2000 10:36 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I would like to register my vote as above. - Gaurang Shah ASTON Consulting


Author: "June Shank" at Internet Date: 04/25/2000 1:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I'm in favor of full disclosure to all investors. June E. Shank


Author: Leo Shebalin at Internet Date: 04/25/2000 10:28 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents No on selective disclosure. Leo V. Shebalin


Author: at Internet Date: 04/25/2000 2:27 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD:File No.S7-31-99 ------------------------------- Message Contents Sirs: Economic justice is as important as political justice. Selective disclosure is unjust. Do we have a democracy or do we not? I am a retired history teacher and a small investor - "fair play" is supposed to be central to our way of life. Selective disclosure should be eliminated. Yours truly, Barry N. Sisk


Author: "Paige Smith" at Internet Date: 04/25/2000 10:14 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents In regards to selective disclosure, I believe that this policy at one time had a place in society but that was a long time ago. In the modern day of technological advances, information is easily and readily available. Before anybody should make any decision that will affect their life, the person should spend the time and effort to weigh all options and fairly evaluate all information that they have collected. To allow selective disclosure to continue is wrong. Please allow people the freedom that this country is known for, to make their own decisions like mature, responsible adults who are accountable for their own actions. Thank you for your consideration in this matter. Jacqui Smith 3875 Hopyard Road, Suite 160 Pleasanton, CA 94588


Author: "tempor" at Internet Date: 04/25/2000 10:55 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I realized that I had not signed my earlier mail, and since it is possible that the SEC may have some requirements in the matter of signed opinions, I am forwarding the same message, with my electronic signature. Thanks for lending an ear! R. Sundar I believe that the SIA has put forth some arguments to dissuade SEC from going ahead with the "FD" requirement. Though they have every right to fend for the survival of their members, they appear to have appropriated the right to pronounce on what the common individual investor may or may not need, to make the right decisions! The following items are specific responses to their rather insolent stand. 1) The SIA claims that "analysts perform a necessary and valuable function in the U.S. capital markets"! Analysts are employed by security firms, and not legislated or mandated by SEC! They are not there to serve any altruistic purpose, either. They have to perform in such a manner as to increase the returns for the concerned securities firm, otherwise they may have to find some other employment. The market can well perform without these "analysts". In fact, I strongly feel that the market will perform much better and more rational without them, based on the distorted ratio of buy-to-sell analysts' recommendations alone! 2) SIA claims that analysts "need better information than the participants in the market"! They have unfortunately taken the stand that the security firms are somehow more equal than the individual investor in the world of investing. Though this is a free country, and a financial analyst or any other legitimate professional has a right to trade his or her ware, to claim that such a professional needs pre-emptive access to information that will eventually be public just so they can make a living sounds so ridiculous, that it is surprising that they even raise such an issue in the first place. Once again, financial analysts are not in the business of saving lives or protect national security, to demand privileged access to information. 3) The SIA has taken a preposterous stand that "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". The SIA should sooner or later understand that prospectus and periodic reports (such as 10-K and 10-Q) are meant for the individual investor to "pore over"! This exercise is very much part of the "due diligence" exercise of an individual investor, who is solely responsible for his or her own investment decisions and entailing risks. The logical conclusion to what the SIA says is that prospectus and periodic reports need not be made available to the common shareholders and public at large, since they are not qualified to "pore over" such documents! It does look like that it is the SIA that is out of sync with the real world, after all! 4) The SIA is opening a can of worms when it asserts that "analysts make the markets less volatile". Any one with reasonable intelligence following the last few years of the financial markets would know that just the opposite has been happening! The financial news media is replete with analysts' recommendation changes on a daily basis, and many of these recommendations have caused dramatic changes. This is a real "catch-22" situation for the analysts. If the recommendations do not have any impact on the market, then such recommendation is worthless to their employers. In fact, the higher their impact on the market, the more revered they are (example being the recent slide in the market attributed to one famous analyst, who is probably proud and certainly has not disputed the media). And here is the SIA claiming that their existence should somehow be protected because they do the opposite! 5) The SIA's assertion that "analysts spend much of their time ferreting out negative information about companies" may not stand up to even modest inquiry, based on the "buy-to-sell" bias of recommendations alone. If the analysts were truly unbiased, their recommendations should be similar to market movement, if we are ever to believe in any kind of efficiency of the market. It is up to the SEC to decide whether the market in inefficient, or whether it is the analysts, since they are surely not in sync. R. Sundar


Author: at Internet Date: 04/25/2000 2:00 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Full disclosure to ALL NOW! Mark C. Tafoya


Author: "kenneththom" at Internet Date: 04/25/2000 11:12 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents All information should be shared with entire public. As a potential or current share holder I want access to all information directly not through a second party Thank You, Kenneth Thom


Author: "John Turgai" at Internet Date: 04/25/2000 1:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents Please stop selective disclosure. Sincerely, a concerned investor, John Turgai


Author: "Guenter Viktor" at Internet Date: 04/25/2000 11:08 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Proposed Regulation FD: File No. S7-31-99 ------------------------------- Message Contents I would like to express my opinion regarding subject regulation, and urge you to pass it. I can not see any reason why companies are able to selectively disclose important information -- such as upcoming earnings figures -- in conference calls or meetings that are open only to selected securities analysts and/or institutional investors, and which exclude members of the public and the media. As a shareholder, or potential share holder, I should have access to all information about a company as soon as it is available. Sincerely, Guenter Viktor 10015 E Mountain View Rd Scottsdale, AZ 85258

http://www.sec.gov/rules/0425b06.htm


Modified:05/10/2000