Author: "William Aldrich" at Internet
Date: 04/26/2000 9:55 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hello,
I am in favor of the proposed legislation to have companies give important
information to Wall Street analysts and the public at large simultaneously.
Yours,
Bill Aldrich
Author: at Internet
Date: 04/26/2000 9:36 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Dear Sirs:
Please level the securities playing field by requiring full public
disclosure of information by public companies. I think the new proposed
regulation is just what is needed. Thanks!
Regards/Ed Arenz
Beyond Communications
612-444-7909
Author: Bob Armstrong at Internet
Date: 04/26/2000 9:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents
I am strongly in favor of this regulation. Robert D. Armstrong, Arnold,
Ca 95223
Author: "J. David Arnold" at Internet
Date: 04/26/2000 9:08 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents
Please give us small individual investors the same break
given to the likes of Soloman Bros.
Until a truly independent "Consumer Reports" type of
orginization comes along to be wholly abstractive in their
opinions, let the individual have the same information and
decide for himself.
Until the analyst community scraps their obviously
self-serving ranking systems and most especially rarely
placing a "Sell" on a security, I can't have much faith in
their recommendations.
J. David Arnold
4413 Chandler Lane
Virginia Beach, VA 23455
Author: john bauer at Internet
Date: 04/26/2000 10:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
john bauer, individual investor , is for a level field and full
disclosure to the public and there by supports the proposed regulation.
Author: Tom Befumo at Internet
Date: 04/26/2000 6:03 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Full Disclosure is needed for ALL investors!!!
Tom Befumo
Befumo Insurance Group, Inc.
Author: "Gregg Bodell" at Internet
Date: 04/26/2000 7:43 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Full Disclosure Please! We are talking about money here. Would you
purchase securities with a blindfold on your eyes? I would rather do my
homework reading the SEC currently required documents. In fact, why doesn't
the SEC look into requiring more information.
As a citizen and as a stockholder, my voice is for Full and Complete
Disclosure at all times.
Gregg Bodell
gcbodell@hotmail.com
Author: "han shin" at Internet
Date: 04/26/2000 10:36 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
Han Shin
SUNY- Buffalo
Author: MACH 2 at Internet
Date: 04/26/2000 10:22 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I would like to register my vote in favor of the SEC implementing fair
disclosure rules.
Cheryl R. Bullard
Lockheed Martin Aeronautics Company
Author: at Internet
Date: 04/26/2000 10:34 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Level the playing field!
Alfred Erich Bussian
Author: "James Camou" at Internet
Date: 04/26/2000 6:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
26 April 2000
Dear Sir or Madam;
I wish to add my comments in favor of full disclosure to the collection that
you are assembling.
I have recently read an analysis of the Full Disclosure regulations that was
prepared by the Securities Industries Association, and I find the positions
a bit incredulous.
1) Is it true that "it hardly needs saying that analysts perform a
necessary and valuable function in the U.S. capital markets"? Is it true
that to perform that necessary and valuable function they need better
information than the participants in the market?
Nothing in the proposed Full Disclosure regulations will stop any analysts
from performing any supposed "necessary and valuable function in the US
capital market". Without Full Disclosure, many individual investors find
restrictions placed upon their ability to perform their necessary and
valuable functions in the US capital market, and they are essentially forced
to play on a non-level playing field.
2) Is it true 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"?
This implies to me that the Securities Industries Association is in
opposition to the warnings that individual investors should read company
prospectuses and reports prior to investing any money. This should be what
happens in the so called real world today, and Full Disclosure would only
better enable that discovery process for the individual investor who chooses
to do their own due diligence.
3) Is it true that analysts make the markets less volatile?
There are no facts to back up this statement. In fact, the market has
demonstrated periods of volatility especially recently in a condition where
Full Disclosure is not required, and the analysts should have supposedly
moderated such volatility. I suspect that a majority of the analysis that
has been performed recently did little to moderate the market volatility,
and in some situations a case may be made that such analysis contributed to
the volatility.
4) Is it true that analysts spend much of their time ferreting out
negative information about companies?
It has been my experience that I very rarely see negative information on a
company until such information is fairly public domain. As the analysts
depend upon the good graces of the companies for their sources of
information, there is a structural impediment to performance of this stated
function.
There is nothing in the proposed Full Disclosure regulation that is intended
to reduce the amount of communication between companies and analysts, the
intention is only to make the communication public. There is nothing in the
proposed Full Disclosure regulation that is intended to reduce the role of
the analyst, or impinge upon the analysts job performance, the intention is
only to make the same information available to the public who may choose to
take note. Informed investment decisions have always been based upon broad
access to accurate information, essentially applying free trade rules to
company communications.
Regards,
James Camou
San Diego, CA
Author: "Diane Cox" at Internet
Date: 04/26/2000 7:31 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I support the new regulation requiring giving all information to the public
and not just Wall Street. It is extremely important that I can obtain all
information that my broker does so that I can make informed decisions about
my investments.
Diane Cox
Cox International
205 Winslow Avenue
Rialto, CA 92377
Author: "adavid2426" at Internet
Date: 04/26/2000 6:36 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Dear Sir,
I believe that is in the best interests of all stockholders to have the
information about each company available at the same time it is available to
major investors. I strongly support this need and wish to let you know my
position.
Sincerely,
Anne Davidson
adavid2426@msn.com
Author: Beverly B Davis at Internet
Date: 04/26/2000 11:18 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents
I am writing concerning the proposed regulation that would allow equal
access to information to all people willing to invest their money in the
market. That the brokers do not want this in order to protect their
"options closed market" is only reasonable from their standpoint. For
the first time in the history of this nation we have the opportunity to
equalize this opportunity for true wealth building both for the
individual investor and those in whom he is investing. The walls should
come down that deny information to all but a select few. The brokers
will continue to do plenty of business with the many, many people who are
unable or unwilling to do their own research and investments.
Considering all those who have lost money lately, they may be busier than
ever no matter how much information is out there for all. Do not allow
the proposed regulation to be lost to whining analysts claiming only they
can perform "a necessary and valuable function in the U.S. capital
markets".
Sincerely,
Beverly Davis
Secretary/Treasurer for R. W. Davis Construction, Inc.
Author: at Internet
Date: 04/26/2000 10:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
It is my understanding that the SEC is accepting comments on Proposed
Regulation FD.
I am strongly in favor of providing individual investors equal access to
company announcements and strongly against giving preferencial information to
analysts and institutional investors. This places the individual at a
disadvantage in taking responsibility in their own investments.
Edwin Davis
Author: at Internet
Date: 04/26/2000 7:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs/Madames:
Please pass the proposed regulation and, indeed, level the playing field so
that owner of a public company may get information about their company in a
timely manner. Analysts, who may benefit from the information, should not
have prior access. Thank you.
Sincerely,
Loren H. Dill
Author: "Cecil Dorsett" at Internet
Date: 04/26/2000 9:14 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Sirs,
Please level the playing field. It is time to stop selective disclosure and
allow all investors the right to access the same information at the same time.
Thank you,
Cecil R. Dorsett
Author: "Randy Eppinger" at Internet
Date: 04/26/2000 10:11 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I'm not an investing expert. I'm not a professional investor. I believe in the
American Dream, and I work hard every day for my money. I am investing my money
in companies I believe in, but that requires that I have as much information
available to me as possible. Allowing companies to give important information
to Wall Street analysts without simultaneously giving the news to the public at
large sounds a lot like insider trading to me. But, as I said, I'm not an
investing expert.
Randy Eppinger
Author: Rob Ericsson at Internet
Date: 04/26/2000 6:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
This is a good proposal and is step towards empowering individual investors.
With the recent migration away from defined benefit retirement plans towards
defined contribution plans (e.g. 401k) it is more important than ever that
individuals have free access to all possible information about their
investments. There are too many temptations to exploit information
asymmetries for the gain of the professional investment community at the
expense of the individual investor. Investment information about publically
traded companies should be available equally to all.
Rob Ericsson
Author: "Michael Fain" at Internet
Date: 04/26/2000 10:06 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I strongly agree with Securities and Exchange Commission Chairman Arthur
Levitt with regard to the proposed regulation "FD: File No. S7-31-99" when
he 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...."
He was correct in saying, ".... The rules we passed today are positive steps
in the direction of even greater integrity in the financial reporting and
public disclosure process."
Thus, I support and endorse final approval of the new rules.
Thank you, Michael Fain
2412 Wertherson Lane
Raleigh, NC 27613
tmfain@bellsouth.net
Author: Dave Freitag at Internet
Date: 04/26/2000 6:25 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I fully support this rule to eliminate selective disclosure.
As a private investor using an on-line trading account, I want the
playing field leveled.
David B. Freitag
(425) 641-2847
Author: Robert Frostick at Internet
Date: 04/26/2000 10:35 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Level the playing field and make it so the analysts and the public at large
get the same information at the same time. Change the current rules.
-------------------------------------------------------------------------------
Name: Robert Frostick
Email: bfrostic@access.k12.wv.us
-------------------------------------------------------------------------------
Author: at Internet
Date: 04/26/2000 8:02 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I feel it is time to level the playing field between Individual Investors and
Wall St.
I have been a self taught investor for quite some time now and have done
quite well for myself. The only time I feel that I have made mistakes was
when I relied solely on Brokers advice of Analysts advice, I have learned my
lessons well, these people do not work for me, but for themselves and the
Companies that they analyze.
Very truly yours
Daniel F Frys
Author: at Internet
Date: 04/26/2000 6:13 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Please take this e-mail as a strongly opposed vote for selective disclosure.
As a prudent investor, I request that you reject selective disclosure.
Sincerely,
Martin Good
Personal Investor
Author: "Hugh Goodrich" at Internet
Date: 04/26/2000 6:28 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Gentlemen:
As an individual investor, and as a former 16-year veteran stockbroker with
Merrill Lynch, I would like to voice my strong opposition to selective
disclosure. It is evident to me that this practice is patently unfair to the
broad spectrum of investors and it should be abolished.
Very sincerely yours,
Hugh Goodrich
3305 Brimm Street
Marshall, TX 75672
Author: "RF" at Internet
Date: 04/26/2000 11:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Regarding Securities Industry Association assertions regarding the proposed
regulation, there is a substantial amount of information on the internet,
which I feel has helped level the field of privileged information formerly
held by brokers, contrary to their views that "potential investors poring
over prospectuses and periodic reports is highly theoretical and out of sync
with the real world." That information can be and is accessed by me, and
I'm certain many others, to help in determining stock acquisitions.
Imposing the proposed regulation would add additional help, and allow me to
analyze, rather than let the 'experts' analyze and 'guide' me on 'selective
disclosure' of material corporate information, only they are privy to.
I am definitely for the imposition of the noted regulation.
Thanks,
R.F. Graver
'A semi-informed investor'
Author: at Internet
Date: 04/26/2000 10:05 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
I tend to lean towards acceptance of the elimination of selective
disclosure. I believe that as an investor, there is a responsibility to
dealing with the information involving your investments. The lack of
"material" information that comes from this is to me as if you were buying a
car with brakes. But the type of brakes were only disclosed after you had
paid for the car and let your friend know that you had purchased the car, at
which time you would find out that hey I have ABS, or no it's a drum roll.
To most people buying a car, the lack of information involving an such an
integral component would be enough to infuriate them, and cause them to
reconsider. In the market, no one gives it a second thought, it just is!
If you were making an cake and the cake instructions were not to be read
until you had put it in the oven, how could you anticipate what your cake
was going to be, chocolate, yellow, angel food?
In this case, for example the potential earning estimates, could that not be
construed as "material" information, or is it a inside information that
could be taken for insider trading? I would like to think that honesty and
honorablity are the legitimate reasons for the disclosures that are deemed
"selective." But how honest is a person going to be when you tell them
about a gold mine in your landlord's back yard, show them where it is and
give them the equipment to excavate it, then tell them not to tell anyone
else, until you can mine it? I see the corporations as those miners, who
are telling these analysts about this mine. Why not tell the less "worthy"
owners of this property, here the shareholders, both large and small, about
this mine and let them decide what to do about it? To me this seems like a
clear fiduciary duty of the corporate entity to it's rightful owners.
I am in agreement to the support of this act, and I think that the
disclosure of information would allow a "private" investor a better idea of
how the market of corporate ownership can make the potential investment a
reality.
Thanks
Andrew Hakes
Author: "Matt Hammerstein (Yahoo)" at Internet
Date: 04/26/2000 8:34 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To whom it may concern:
I am a second-year MBA student at the University of Chicago. During the
summer between my first and second years, I interned in the equity
research department at Morgan Stanley Dean Witter. As such, I observed
first hand the impact of the proposed regulation. During one particular
trip, my supervising analyst and I visited a company to review a
valuation model we were preparing. During this meeting, company
officials guided our model assumptions signficantly, with their opinions
of the company's future prospects. This information was immensely
valuable in our efforts. And, while the information then became public
information, it would be nearly impossible for any individual investor
to gain similar information access, unless they could subsequently gain
a copy of the analyst's report. Even then, however, an individual would
likely only gain the information after the analyst had already
communicated the information to numerous buy-side analysts, and also at
a substantial cost.
As an active individual investor, this scenario concerned me
considerably. While I am not a daytrader, and therefore do not trade on
specific pieces of information, instead picking companies I believe to
be a great long-term investment, I still find this situation deeply
troubling. It is also a situation of which I believe many individual
investors are completely unaware. While private entities, like the
Motley Fool, are doing their utmost to change this situation, it remains
that the lack of this legislation leaves the individual investor at a
disadvantage.
Consequently, I would strongly urge the SEC to adopt the proposed
legislation without a second thought. Lastly, like the Motley Fool, I
think the SEC needs no other information than Wall Street's stern
opposition to the proposed legislation to understand just how much the
legislation is needed.
Thank you for your time.
Matt Hammerstein
Concerned Investor
--
***********************************
* Matt Hammerstein *
* 831 W. Wrightwood *
* Chicago, IL 60614 *
* (773) 477-9830 *
* matt_hammerstein@yahoo.com *
**********************************
Author: "Gabriel Hammond" at Internet
Date: 04/26/2000 11:10 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
Please change the regulations so that companies can no longer give important
information to Wall Street analysts without simultaneously giving the news
to the public at large.
Gabriel Hammond
Author: at Internet
Date: 04/26/2000 10:39 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD: File No. S7-31-99
------------------------------- Message Contents
Selective Disclosure is not something that should be tolerated in a
fee and open market. Please act to level the playing field for all investors.
Author: russ hatfield at Internet
Date: 04/26/2000 5:40 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am adamantly opposed to selective disclosure. I am not sure what the
benefit to the public is, but, if you are not going to share this
"selective disclosure' with us commoners that pay the bills, then it is
wrong.
I urge you to not approve this regulation.
--
Russ Hatfield
3843 Canonita Drive
Fallbrook, Ca. 92028
Author: at Internet
Date: 04/26/2000 7:30 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe that the Federal Government should change the regulations to require
that all companies make all financial disclosures to the public at large at
the same time that the Investment Banking elite on Wall Street finds out about
them. There is no legitimate rationale that can be used to justify the
current policy, and I am glad that the SEC is taking this issue so seriously.
I hope that you do the right thing for the people who need your protection the
most - the Individual Investor.
Chris Hensley
Author: at Internet
Date: 04/26/2000 8:18 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To whom it may concern:
I disagree with the statements made by professional analysts on Wall Street
regarding their perceived greater ability to "ferret out negative
information" about a company. I have been learning about the stock market
and investing my own money for the past 6-7 years, and from what I can see
over the course of this time, the analysts are rarely correct, they do not
share negative information with the average investor, and the market would
have fewer ups and downs without their comments in the national media! I
suspect, as do many self-informed investors, that their desire to retain
their explicit hold on this information is their claim to "fame" and power,
and that they have a vested interest in maintaining the status quo. I vote
for more open information, available to all who have a desire or need to see
it. Sincerely, Marsha A. Hill
717 Main St./Halstead, KS 67056 (316) 830-2236
Author: at Internet
Date: 04/26/2000 10:34 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation: File No. S7-31-99
------------------------------- Message Contents
I strongly support any and all regulations such as this one to stop giving
special interest to individuals or companies.
Richard L. Hobbs, CEO
Grass Roots Strategies
Author: "Pat Hogan" at Internet
Date: 04/26/2000 7:29 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: file number S7-31-99
------------------------------- Message Contents
Hi,
I don't understand your motivation to allow the "special analysts" to
have data that could allow them to take advantage of me. What possible reason
can you give for this total unfairness. It is time to take a look at reality in
the current state of communication and data tranfer potential.
Please bring information fairness to our markets. It is your duty.
Regards
Pat Hogan
Author: at Internet
Date: 04/26/2000 9:56 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I fully support the SEC's proposal that would make any information given by a
company be provided to one and all.
Bob Hollander
Author: at Internet
Date: 04/26/2000 11:03 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am an individual investor and wish to declare my support of Proposed
Regulation FD. Analysts and small analyst groups are most often investors as
well. ALL investors should have access to material information from an
issuer. The current process of face to face, telephonic, and Internet
meetings should continue and be encouraged to be unanimous so that ALL
investors have the right to be in attendance at these meetings so as to
receive the same information at the same time. Of course, each investor or
group of investors has a choice of whether or not to attend.
Issuers must disclose material information when their insiders know it.
Disclosure must be timely, fairly presented not skewed (spun), and available
to ALL investors at the same time. Investors show their confidence in the
issuers when they invest their money (whether invested individually or by
representatives such as Institutional Investors), and so issuers logically
owe the same confidence to investors when disclosing material information.
And let's get the information to be meaningful, not just cleverly worded
target earnings' statements that try to influence the current stock price.
Sincerely,
Tom Horne
Evanston, IL
Tom
Author: at Internet
Date: 04/26/2000 9:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Keep the us all informed!!
Brian Johnson
FOOL at heart
Author: Terry & Rosanne Johnson at Internet
Date: 04/26/2000 8:02 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed REgulation FD: File No. S7-31-99
------------------------------- Message Contents
Don't keep us in the dark anymore. Open up and let the ''little guy''
have the same information that the ''big boys'' use to help wipe out
what the ''little guys'' invest inorder to get ahead.
It's time that the ''leaders of this country'' start leading for the
people of this country, not just the ''big boys''.
Terry R. Johnson
Author: "vkeith" at Internet
Date: 04/26/2000 10:05 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed regulation FD File No S7-31-99
------------------------------- Message Contents
Right on, Vivian Keith
Author: "vkeith" at Internet
Date: 04/26/2000 10:09 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No S7-31-99
------------------------------- Message Contents
I am opposed to selective disclosure.
Vivian Keith
Author: "Wayne R. Kelsey" at Internet
Date: 04/26/2000 9:02 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No.S7-31-99
------------------------------- Message Contents
Comment: NO!
Wayne R. Kelsey
W3 and Associates
13085 W. Illinois Drive
Huntley, IL 60142
Author: "Ketterer; Robert M." at Internet
Date: 04/26/2000 10:04 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
The current system is not only bad for individual investors, but it is bad
for the markets as a whole. The ability of companies to selectively disclose
material information to some sources and to receive good coverage as a
result makes for a mockery of free flow of ideas and information.
Information needs to be available to everyone, on a level playing field to
enable a true and free market.
Thanks,
Robert
Robert Ketterer
1801 Augustine Cut-off
Wilmington, DE 19803
ketterrm@acwilm.com
Author: jeffrey klass at Internet
Date: 04/26/2000 7:04 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation fd: file# s7-31-99
------------------------------- Message Contents
Its about time the playing field was leveled. NO to
selective disclosure. This is America, for cryin out
loud!
J Klass,
individual investor, and citizen of the U.S.A.
Author: "Karen Kozlow" at Internet
Date: 04/26/2000 10:20 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Everybody should have equal access to information. That is what democracy
is supposed to be all about.
The playing field should be level.
K. Kozlow
k.kozlow@worldnet.att.net
Author: "Bradley C. Kuszmaul" at Internet
Date: 04/26/2000 8:50 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hello,
I am writing this email to convey to the SEC my comments on the
proposed rule to stop selective disclosure, and a few related issues.
I am currently on leave from Yale University, where I am Assistant
Professor of Computer Science and of Electrical Engineering, to work
at Akamai Technologies as Senior Research Scientist. As an individual
investor, I want to see the stock market become a more level playing
field.
I am in favor of the proposed rule to ban selective disclosure.
I also believe that it will be helpful to clarify the scope of insider
trading prohibitions. In particular, as a corporate insider, I would
like to have some formula I could follow that help to insulate me from
suspicion of insider trading. For example, suppose that on May 1st, I
were to provide written instructions to my broker to sell some stock
on May 7th. Suppose further that as of May 1st I had no insider
information, but that I received insider information on May 5th. If
the insider information would have a positive effect on the stock
price, may I allow the trade to proceed, or must I contact the broker
and cancel the instructions? What happens if the information would
have a negative effect on the stock price? Would I be allowed to
contact the broker to cancel the trade (a sort of "insider
non-trading" problem?) It seems to me that it would be fair if the
rules allowed me to give advance instructions, but only if those
instructions were irrevocable. It doesn't really matter very much to
me what the rules are on this as long as there is some way that I can
demonstrate that when I make a trade that that I didn't exploit
insider information.
A related issue is that I believe that certain corporate insiders
should be required to publish, in a public forum, their intent to
trade stock in their companies. My understanding is that certain
corporate insiders are currently required to announce their trades
after the fact, but that there can be up to a 40-day delay before the
trades become public knowledge. That 40-day gap is crucial. I think
that the trades should be announced in advance. I think it would be
fair to give the corporate insiders a certain amount of leeway, so
rather than being required to state "I will sell 100 shares of XYZ on
May 7", they would be allowed to state "I will sell 100 sahres of XYZ
between May 1 and May 15". I think that this kind of preannounced
trade ought to help immunize the corporate insider from insider
trading suspicion.
Here is an issue that is even more tangential, but could help to level
the playing field further. One objection that the SIA raised to
proposed Regulation FD is that people who are on the trading floor will
always have better knowledge than people who are away from the floor
working a non-Wall-Street job. [The SIA objection that "there is no
way to be completely fair, so why bother with rule FD" seems not to be
worth rebutting.] I propose the following major change to the stock
market that would reduce the importance of being on the trading floor.
The stock trading system should be modified to perform all the trades
in a synchronous fashion. Here is example of what I mean by
"synchronous" trading:
- A central order booking mechanism is established for all stock
trades. The central order booking mechanism is a computer.
- The mechanism receives trade orders, but doesn't execute them
immediately. Instead it accumulates trade orders for up to five
minutes. When the time is on a five-minute boundary (e.g., 9:05,
9:10, 9:15, 9:20, etc.) then the mechanism calculates the feasible
trade price. (The system encourages investors to place limit
orders.) All feasible trades then execute, and all at the same
price. (There are several important papers in auction theory that
show how best to compute the feasible trade price so that it works
for all situations.)
- The system does not publish anything about the trades that didn't
execute.
In contrast, the current system is "asynchrounous". Trades happen
without regard to any external clock.
Advantages of such a synchronous trading system include:
- A synchronous system has the advantage that investors participating
over the internet have the same information and opportunity to
trade as the wall-street insiders. After seeing the price at which
stocks trade, and receiving any news about the company, everyone
would get five minutes to make up their mind about the value of the
stock and place their trade, which is plenty of time for almost
everyone to participate. Being 1 minute away from the trading
floor would confer no disadvantage.
- The price is based on what actual investors are willing to pay for
(or receive for) a particular stock, rather than going through a
level of indirection in which market makers establish the price. I
think it must be better to have the price set directly investors.
I would expect market makers to object to this system, since they
are the primary beneficiaries of using an asynchronous system. A
synchronous system would prevent "feint-and-switch" trading where
market makers manipulate an asynchronous system by posting an offer
to buy, and then immediately revoking the offer, and then taking
advantage of the "market momentum" induced by their bogus offer.
- The system encourages investors to place limit orders, since limit
orders would be executed at the same price as any other executed
order. The current current system discourages limit orders because
typically limit orders are executed at an ECN or in some other less
efficient market as compared to the market for unadorned orders.
If the market were largely driven by limit orders, then it would be
more stable.
- The system could implemented with a relatively small amount of
computing power, and would be less likely to become overwhelmed by
large trading volumes. [For readers familiar with database
technology: The idea is that one large atomic database transaction,
comprising many trades, is much cheaper to implement than a separate
small atomic database transaction for each trade.]
I realize that my proposal constitutes a major change to the stock
market mechanisms, but I believe that a change of this nature would
make the stock market itself into a completely level playing field,
while reducing instability, and improving the efficiency of the market
by providing a central order book mechanism.
Sincerely,
Bradley C. Kuszmaul
Prof. Bradley C. Kuszmaul
Yale University Department of Computer Science
and Department of Electrical Engineering
(on leave at Akamai Technologies until 12/2000.)
US Mail: P.O. Box 208285; New Haven, CT 06520-8285
Street address: 51 Prospect Street; New Haven, CT 06520-8285
email: bradley@ee.yale.edu
web: http://ee.yale.edu/~bradley
voice: 203-432-6400
fax: -0593 (shared fax machine)
Author: "Paul Lagris" at Internet
Date: 04/26/2000 6:28 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed regulation FD: file # S7-31-99
------------------------------- Message Contents
I want a voice.
Paul LaGris
Converging Solutions, Inc.
Author: Sean Jennings at Internet
Date: 04/26/2000 6:56 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
This country did not become great as a result of selective disclosure,
or any other form of enforcing an unfair edge so that special interest
groups -- like analysts who get information shareholders don't -- can
thrive at the expense of the population as a whole. Selective disclosure
hurts investors, and hurts the economy as a result, so that a few people
can maintain their parasitic positions. Please think over this
regulation very carefully before you decide what is in the long term
best interest for all Americans.
David Langford
Author: Pete Larson at Internet
Date: 04/26/2000 7:11 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Giving information selectively to analysts and not the public at large
is wrong! Individual investors like myself definitely want and deserve
comprehensive, timely information about public companies.
Pete Larson
PKLaughs@home.com
Author: at Internet
Date: 04/26/2000 10:45 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please reconsider any bill that would limit the information disclosed to
individual investors. As recent severe fluctuations in the market indicate,
no one analyst or brokerage house has all the answers. Giving crucial
information only to analysts only benefits these analysts and their specific
clients, and reinforces the notion that the market only exists to serve
people/institutions that are already rich. An individual's decision to
participate in the market is in part influenced by the following: do I trust
that I have the same information as large investors? Individual investors
are quite capable of reading and understanding complex documents, so that
should not be an argument. Sites such as the Motley Fool have excellent
glossaries to guide us if words are unfamiliar. Therefore, in order to carry
out what I believe is your goal, to have more individuals invested in the
market, give them an important reason to trust a market that is based on
equal access to information.
Rhonda Lees
