Author: "Toma B" at Internet
Date: 04/30/2000 1:09 AM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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In favor of proposed rule.
toma berishaj
user of E*Trade
Author: at Internet
Date: 04/30/2000 11:51 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I support the proposed change.
As an individual investor with no corporate affiliation I am disadvantaged
because the trader on the other side may have additional information not
available to me. Any profits accruing to the favored firms can only come at
the expense of us small, individual investors.
R. C. Blackburn
25 Fountain Rd.
Levittown, PA 19056-1914
Author: at Internet
Date: 04/30/2000 9:30 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. s7-31-99
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Greetings: Information should be available to all investors, not just the
institutions and brokers' analysts. James O. Bleidner
Author: "goghd" at Internet
Date: 04/30/2000 10:27 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: ProposedRegulation FD: File No. S7-31-99
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Please stop the Selective Disclosure rules and allow us the individual investor
equal and timely access to information. I'm a shareholder just as the big wall
street guy is.
Gary Dahl
Alexandria VA
Author: at Internet
Date: 04/30/2000 2:24 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Please help open the doors to individual investors. It is an insult to us
all to believe we cannot control our own destiny. It is bad enough the govt.
takes a sig. percentage of our earnings and allows us no say in how they are
invested or our rates of return. Do not let the investment community hold
all the cards,
Scott Falvo
15 Cantilena
San Clemente CA 92673
Author: "Connie Glasgow" at Internet
Date: 04/30/2000 11:46 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg. FD File S7-31-99
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Proposed Regulation FD File S7-31-99
I am in favor of this proposal to end selective disclosure.
Rich Glasgow
Author: at Internet
Date: 04/30/2000 11:54 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Are they kidding? The idea of selective disemination of information is
ridiculous. Are the "haves" really that powerful? I favor Proposed
Regulation FD: File No. S7-31-99. Have some balls, support the guys who pay
for the ride.
Sincerely,
Garth R. Jackson
409 Plymouth Road, Ste. 200
Plymouth, MI 48170
734.416.9000
Author: "Gregory Kent" at Internet
Date: 04/30/2000 8:12 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I favor Proposed Regulation FD: File No. S7-31-99
Gregory C. Kent, Jr.
Am Zunftackerrain 12A
Pratteln, Switz. CH-4133
Author: "Larry Knerr" at Internet
Date: 04/30/2000 2:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-31-99
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Dear Sirs,
I just learned of your proposed Fair Disclosure Regulation. This comment may
not beat your deadline, but I still wish to contribute my two cents.
I, like many others, have lost (or not made) a great deal of money because
market insiders had privileged access to information and took advantage at the
expense of smaller investors. I have always found the system unfathomable -
how can a company, which I supposedly partly own, have so little responsibility
to represent my interests? Therefore, I enthusiastically support your proposed
rule. It goes a good way toward the goal of a fair stock market, where success
depends on the ability to choose stocks rather than to profit from inequitable
access. My experience with discussion boards and conference calls covering
small companies suggests the average investor understands them far better than
the average analyst - another reason for investor parity to increase market
efficiency.
I have been reading some of the other comments submitted:
First, in regards to Charles Schwab & Co's proposed 'clarification' - that the
rule should apply strictly to intentionally provided information known to be
material:
1.) Almost all information provided selectively has the potential to be
material (else why provide it?).
2.) By Schwab's own 'ex ante' argument, almost none of it would meet the
requirement above. Setting the bar so high effectively guts the rule.
I see no point in having a rule that diluted.
Second, I agree with the NIRI that (written, freely available) publication of
material information on the Internet can be considered an acceptable method for
achieving full and fair disclosure. Also, the ease of doing this is an obvious
counter to the fear of the 'chilling' the rule might cause. It will certainly
'chill' the SIA and others who make a living through differential access to
information, but that's a good thing.
I disagree with some of their other points, however:
1.) They seem to argue that voluntary guidelines are working and public
disclosure has improved, therefore selective disclosure must be diminishing.
The last doesn't follow and is not my personal experience.
2.) They argue that responsibility should be shared between those who
disseminate selective information and those who use it while at the same time
saying the Dirks decision has tied the SEC's hands in dealing with the latter.
So. -what? -nobody need be responsible?
3.) They state that confidentiality agreements with analysts won't work. The
UKLA has had the opposite experience, but even if it's true how hard can it be
to delay the answer to an analyst's question until it can be made available
publicly? "I'll get back to you" - rocket science!
Your proposal is a really good way to make the stock market fairer. I hope you
will be able to implement it soon (or as soon as you have considered all the
comments carefully and polished it up in their light). Good luck.
Yours,
Larry Knerr
Author: at Internet
Date: 04/30/2000 9:05 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: I favor Proposed Regulation FD: File No. S7-31-99
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I favor Proposed Regulation FD: File No. S7-31-99
Kevin Kunkle
Kunk555@aol.com
Author: "Bernie Langlois" at Internet
Date: 04/30/2000 8:25 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I am in favor of this proposed regulation.
Bernard G. Langlois
Safety Harbor, Florida
Author: "tiny leseck" at Internet
Date: 04/30/2000 10:27 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Regulation FD: File No. S7-31-99
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Please be advised that as a small investor I feel I need access to all
information including company conferences to make an informed decision.
Sylvia Leseck
Ingomar, Pa
Author: at Internet
Date: 04/30/2000 10:31 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please stop selective disclosure practices.
Maurice Malone
Delray Beach, FL
Author: "Ruth Parker" at Internet
Date: 04/30/2000 10:40 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation Fd: File No. S7-31-99
------------------------------- Message Contents
I favor this proposed regulation.
Thank you,
Ruth A. Parker
Huntington, Tx
Author: at Internet
Date: 04/30/2000 5:53 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. s7-31-99
------------------------------- Message Contents
Proposed Regulation FD: File No. s7-31-99
I love it!
Mike Ruland
Author: at Internet
Date: 04/30/2000 2:49 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I favor Proposed Regulation FD: File No. S7-31-99
--Aron Sotnikoff
Author: JT at Internet
Date: 04/30/2000 6:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
To Whom It May concern;
This is a comment favoring non selective disclosure of corporate information.
Two aspects occur to the writer: The need (or lack thereof) for intermediates
in the information flow and, second, the element of gaming on the information
'float' period, usually to the advantage of a selected few.
First, one will willingly pay for intermediation where the intermediate adds
value proportionate to the cost of the process. For many investors there is
increasingly a desire to execute their own purchases and sales of securities,
with a minimum of cost in time or dollars. Online trading, whatever one's
personal view, offers you and me the opportunity to determine our target
acquisition or sale and execute it without paying large fees to a
'gatekeeper'. When that gatekeeper adds value to the transaction then most
will gladly pay a fee. However, when the gate becomes merely an impeding
tollgate on the highway then that intermediate agent must disappear. Unless,
that is, those agents can get relief by regulation or law, forcing you and I
to procure their services.
an excellent example exists in real estate today. Real estate agents have long
held that buyers and sellers must go through them for access to the inventory
of properties for sale and, conversely, for property to be included in that
'catalog' one must agree to pay a significant fee. Having pursued this
occupation for a number of years I claim that there are many good reasons to
use an agent beyond inclusion in the catalog of properties for sale. Many of
my Brother agents however took a stand at the 'bridge' of public access to the
catalog data. Fast forward a few years and today any agent with an IQ above
room temperature now exhibits his/her clients properties everywhere there is a
dot-com database. Right alongside the listings of the dreaded For Sale By
Owner. And those agents make a good living. Plus, all those buyers and
sellers now have a full choice of services and fees. PS - the market works
even better now than ever before!!
The lessons learnt? One, there is no sane reason to legislate a required
gatekeeper on information, even at a fee of zero. Two, that good agents have
a heck of a lot to offer the interested client besides a stranglehold on
information needed by others to make cogent decisions about these client's
properties.
I submit that the same case can be made for the securities agents now begging
to retain access to privileged company revelations. The good ones will
survive, even thrive in an open environment. Others will need to take up
honest work. Such is life and progress.
Now, the second reason for my misgiving is the argument for a 'level playing
field'. In your positions as Commissioners, you could take out any senior
broker and strong arm information from them that would give you a huge
advantage in the next day's trading. I suspect you don't because, even today,
there is a sense of fair play afoot and, if not, there are pretty draconian
penalties for the detected transgressor.
The Brokers now getting so called privileged information can do something very
similar with a high degree of impunity. The volume of outcry from the
Brokerage fraternity about your rulemaking makes clear that revenue is very
threatened. Over what? If they are not acting on the information fort large
profit, why the fuss? Ladies and gentlemen, I doubt any of us spent time in
the past few days riding into town on the well known turnip truck. Important,
vested interests are threatened by your potential regulations. You must
decide if the 'old boy' network can continue to modify market forces by
distributing precious information to an anointed few or if you shall enable
full participation.
I suspect that more and more of we private citizens are becoming comfortable
selecting just which services and information for which we will pay. Analyst
reports requiring actual knowlege and spadework will always command a
premium. I suspect that there will be a lot fewer of these 'analysts' in the
near future as their relative skills become known. It is an immutable
statistical property that roughly half of a normal sample population will be
below average.
But allowing a select few 'analysts' the privilege of having information
whispered in their few ears for dissemination to a few more (well paying?)
ears must end. As a shareholder in several SEC regulated companies I insist
that you defend my need for equal - and simultaneous - access to company
information as it is promulgated. I have even heard the old chestnut that the
'special analysts' need to be able to 'read' the intonations and expressions
of the party reporting for a given company. How in the world would having
more ears on a conference call (or viewing a video conference) affect this
process? Well, the 'little people' would have the same information at the
same time. And be able to analyze and act on it in the same time frame as
everyone else. That's bad news for those who use their special time
advantage without really adding value, isn't it?
Sorry, brokers, my 100 shares are more important to me that the 1,000,000 or
10,000,000 which you control for others. I see no reason that I should be
denied equal, simultaneous access to any and all information. Denied is the
operative verb because, right now, I am denied this opportunity by rules that
were placed when disclosure meetings could be nothing except face to face, in
a board room or auditorium.
Technology now removes totally any pretext for relatively ancient rules and
permissions. As we are all aware it is possible to broadcast any talk or
presentation over the Internet to anyone who would want it, even at 14,400bps
for the more rural locales. Some Corporate sites even keep copies of
releases and other audio information for later listening by latecomers.
The software is free, Microsoft Internet Explorer and, for slides over the
same link, MS Netmeeting, are available for *free* in the standard Windows xx
distributions. Macintosh software is also free as are programs under
Linux/Unix. This pretty well covers anyone doing onlline trading!
Please eliminate a bias that is a persistant 'buggy whip' from days of yore,
like even ten years ago!
Thank you
Jeff Thompson
