Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: Dawn Badgley at Internet
Date: 08/09/2000 7:59 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Full disclosure
------------------------------- Message Contents
I believe that Full Disclosure can work for all of us. Those investors
who enjoy researching and analyzing market data can benefit and make
substantially sound decisions with information gathered through full
disclosure. I don't believe it will put anyone out of business because
people will still listen to the analysts. Those who suffer from overload
will only listen to the analysts or continue to trust to fortune. We are
all subject to overload at some point and regarding some subjects. How
is that different from any other topic of available information and why
should this be any different? Each of us absorbs what we can and for
those who can't, we are dependent on the professionals. Myself, I like
accessing both.
Thank you for reading my opinion.
Dawn Badgley
Author: Martin Bennett at Internet
Date: 08/09/2000 6:36 AM
Normal
TO: RULE-COMMENTS at 03SEC
CC: bdawson@qualcomm.com at Internet
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
The fear that Wall Street Analysts losing the ability to manage 'us' the
'little-people' is amazing. I'm one of the many people who have a better
understanding of the technical market than most Analysts. I don't need them
telling me what to invest in and limiting when I can receive information.
Martin Bennett
Business Process Analyst
Qualcomm, Inc.
W) (858) 658-2564
P) (858) 635-0261
Author: at Internet
Date: 08/09/2000 7:30 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Reg FD: File No. S7-31-99
------------------------------- Message Contents
Strongly support change which would make information available to individual
investors at same time as analysts.
Willard M. Burleson
Author: "Cahill; Tim" at Internet
Date: 08/09/2000 11:46 AM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Mr. Katz,
I am writing to express my approval of the proposed regulation
"Regulation FD: File No. S7-31-99."
As the markets open up to more individual investors, thanks to the
explosion of on-line trading and self-service
brokerage accounts, it is more important than ever that information be
allowed to flow freely and quickly among
market participants, to include individual investors. As an individual
investor, I have the majority of my retirement
funds allocated to individual stocks in my portfolio. In order to make
the wisest decision possible, it's vital that I have
access to the same information at the same time as the major brokerage
firms' analysts do. Coupled with my own
research (thanks to the Edgar On-line system), earnings estimates and
other information, currently disclosed
selectively by some companies, help me make the best possible
investing decision at that time.
Contrary to the SIA's belief that I am unable to make my own investing
decisions, I believe I have made some very
wise decisions to date. However, I also only invest in companies that
currently do not participate in selective
disclosure. If your regulation is passed as proposed, I will have a
broader range of companies from which to choose,
and for that I will be grateful.
In the end, I believe the analysts will also profit. At present, I do
not pay much attention to analyst's ratings because
many of them are only rating the companies for whom they also make a
market. This, in my opinion, presents a large
bias in favor of a "buy" or "strong buy" rating. If the proposed
regulation passes and the analysts are forced to add
some extra value to their research, I believe many people will start
to pay more attention to their analysis. The
analysts who are first-to-market with value-added research will be the
clear winner, along with the investing public at
large.
Thank you for accepting my comments, and I trust you will make the
right decision.
Sincerely,
Tim Cahill
5 Adams Ave.
Merrimack, NH 03054
Tim Cahill
Sr. H&W Analyst
FESCo - Fidelity Investments
603-791-8770
Author: "CRONINBRAD" at Internet
Date: 08/09/2000 10:15 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: PROPOSED REGULATION FD: fILE S7-31-99
------------------------------- Message Contents
SELECTIVE DISCLOSURE TO FAVORED ANALYSTS IS INTOLERABLE IN THE INTERNET AGE.THE
PUBLIC, ALL THE PUBLIC, NOT JUST INSIDERS,SHOULD RECEIVE EQUAL TREATMENT.
BRADFORD F CRONIN
Author: "Davis; Brian" at Internet
Date: 08/09/2000 8:50 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Selective Disclosure
------------------------------- Message Contents
Dear sir,
If even one of the four panelists vote against ending selective disclosure,
it will be a sad day for our country. Such a vote would call into question
the panelist's integrity.
This decision will show who is more important and who the SEC is out to
protect, the American people or powerful Wall Street analysts. I can only
hope that they will hear the voice of the people of the United States, and
will vote with their hearts.
Thank you for your time,
Brian T. Davis
Author: "Freeland; Bruce" at Internet
Date: 08/09/2000 10:38 AM
Normal
Receipt Requested
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am in full support of disclosure to all investors, not just "The Wall
Street Elite"
Thank You
Bruce Freeland
freeland.bruce@mayo.edu
Author: Dave Harnett at Internet
Date: 08/09/2000 7:31 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Please vote FOR the full disclosure rule
------------------------------- Message Contents
The USA is built on freedom of information not surpression of
information.
The argument that the individual investor is not "capable" to digest
timely financial information goes against the grain of what the USA
stand for.
Thank you for listening
DAVID J HARNETT
1605 COLUMBIA AVE.
PROT ROYAL
SC 29935
E-MAIL
harnett@gosiggy.com
Author: "Kevin Kay" at Internet
Date: 08/09/2000 9:43 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
This rule has been needed for some time. After being employed by a public
company (ANTEC), I've now had the chance to follow the stock for several
years. It is now fairly easy to predict when major announcments are coming.
All too often, the stock price will make a radical change one day, and an
announcement will appear publicly the next. This is obviously NOT fair
dissemination of information to all shareholders.
Pleae vote yes on this rule.
Sincerely,
Kevin Kay
W. Kevin Kay ("Kevin")
Senior Staff Engineer
Electronic System Products
11450 Technology Circle
Duluth, Georgia 30097
e-mail: Kevin.Kay@antec.com
Phone: 678-473-2100
Direct: 678-473-8624
FAX: 678-473-8797
Author: "Richard A. Kendrick" at Internet
Date: 08/09/2000 9:44 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sirs:
The healthiest market would be one with the greatest amount of
transparency. Keeping this in mind, I urge you to approve the proposed
regulation on the subject line of this message.
Too often I have seen the price of one of my securities drop
precipitously on no news, and then read several days later of
fundamental problems with that company. Clearly, large institutional
investors had this information before it was made public. This is
unethical, and can only create suspicions about corrupt practices
playing a part in America's economy.
Please take the correct action in this matter. Thank you.
Richard Kendrick
McCombs School of Business
The University of Texas at Austin
Author: at Internet
Date: 08/09/2000 11:45 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Re: Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hi. I'm sorry I left my name out.
It is Michael Leviton.
Subject: Proposed Regulation FD: File No. S7-31-99
Author: at Internet
Date: 08/08/2000 3:25 PM
The unprecedented response generated from the public
(individual investors) shows how important we feel this
rule is. It is truly surprising.
What is not surprising to me is Wall Street's reaction.
They try to introduce fear into the debate. I noticed
one comment by John Adams (of Adams, Harkness and Hill):
"Millions of new equity investors will, as a group,
underperform the results achieved by professional
managers."
Considering that the great majority of money managers
(over 80%) manage to trail the market themselves over
long periods of time, his concern for individual
investors is not genuine. Mr. Adams goes on to say that
it is likely that for individuals, "self-management is
hazardous to their wealth."
Mr. Adams really means that self-management is hazardous
to his own wealth. His career and the careers of others
are threatened by those who wish to take command of
their own finances and futures.
Mr. Adams and his ilk are not being honest about their
fees, their underperformance, and now their real reasons for keeping
the current
system of selective disclosure in place.
The SEC now has an opportunity for our nation to take
the world lead in making the People more informed, more
intelligent, and more knowledgable about their affairs.
It is an opportunity that should not be missed.
Author: "Miller; Andra M" at Internet
Date: 08/09/2000 10:07 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear SEC:
Please vote to pass the proposed rule requiring companies
to make information available to the public at large when
they supply such information to Wall St. analysts. As an
investor, I do not need protection from the information they
use in making their investments when I make mine. I should
think some court would find such information channeling to be
unfair -- if not even unconstitutional. It seems prejudicial to me.
-- Andra M. Miller - Apt. 4B
146 West 16th St.
New York NY 10011-6263
*****************************************************************************
The information in this email is confidential and may be legally privileged.
It is intended solely for the addressee. Access to this email by anyone else
is unauthorized.
If you are not the intended recipient, any disclosure, copying, distribution
or any action taken or omitted to be taken in reliance on it, is prohibited
and may be unlawful. When addressed to our clients any opinions or advice
contained in this email are subject to the terms and conditions expressed in
the governing KPMG client engagement letter.
*****************************************************************************
Author: Paul Milligan at Internet
Date: 08/09/2000 10:18 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Yes !!!! Vote Yes !!!! The nonsense about 'people can't manage their own
money', and 'people can't handle the information' is purest crap !
Paul Milligan
2212 Wininger Dr.
Raleigh NC 27603
Author: "Eric Morton ((914) 435-4850)" at Internet
Date: 08/09/2000 8:14 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I support the proposed regulation
Eric Morton
Author: "Michael J. Nagro" at Internet
Date: 08/09/2000 6:53 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
Dear SEC Members,
My wife, Kathryn McPherson and I are both
vehemently opposed to any limitations being proposed on the release of corporate
financial information to the public. As active and informed investors, we
believe we should be able to access the same information as Wall Street
analysts. The Internet, our most crucial tool as investors, democratizes
information. Rather than further an exciting opportunity for small investor,
this proposed regulation reduces our power to manage our financial future
effectively. We do not suffer from any "information overload" regarding our
investments. Indeed, access to charts, reports, and other forms of data only
enhance our ability to make choices. Please do not strip us of that.
Regards,
Michael J. Nagro
Author: "Andrew O'Reilly" at Internet
Date: 08/09/2000 4:57 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Hi,
It would seem to me that the current rules on
disclosure give a closed group of Wall Street
companies what effectively amounts to inside
information. With the internet now affording every
investor with use of a computer instant access to
information on every publicly traded company its time
to change the disclosure rules and open up the
information flow to everybody.
I've heard arguments against changing the selective
disclosure system based on the premise that individual
investors will suffer from information overload. I
find this argument to be completely without merit. The
same computer and internet technology that provides
instanteous access is also providing the tools and
knowledge for individuals to process this data in
highly efficient ways not possible before.
I hope that you all take this opportunity and level
the playing field that is so unjustly tilted against
individual investing people right now.
Andrew O'Reilly
Author: "Trevor R.P. Price; MD" at Internet
Date: 08/09/2000 6:54 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
------------------------------- Message Contents
I am very strongly in favor of new regulation(s) that will prohibit
selective disclosure! I urge establishment of such.
Thank you for your consideration.
Trevor Price, MD
930 Morris Avenue
Bryn Mawr, Pa., 19010
Author: Greg Rambat at Internet
Date: 08/09/2000 8:36 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD File no. S7-31-99
------------------------------- Message Contents
I am writing to voice my opinion of the above proposal. As a fully
functional and breathing adult, I feel I am capable of making the
appropriate investment decisions. In the past I have done what
research I could, but, feel having access to all information readily
available to all at the same time will only make me more successful.
We are not talking about proprietary information. As investors, we are
owners of the companies and should not be excluded or delayed from
receiving any information that assists us i making those decisions.
Selective Disclosure must end now.
Greg Rambat
Lansing, MI
Author: "Ray; Gregory" at Internet
Date: 08/09/2000 9:27 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Sir,
Please support Regulation FD and require that officails of public companies
make all information available to the public at the same time as information
is shared with the investment professionals. Please remember that these
"professionals" are investing "our money". We should have the right to know
what they know as it becomes available...not later.
I have been a private investor for nearly 20 years. My education includes a
BS in Mechanical Engineering and an MS in Chemical Engineering. I am not a
"Wall Street" professional but have followed my personal investments very
closely for years.
During my early years of investing (1985-1991), I worked with a Stock Broker
from Dean Witter and followed his investment advice very closely. He
encouraged me to invest on margin. I watched and followed his advice as the
value of my investments plunged from $88,000 to $4,000. I was very naive
about stockbrokers and their objectives. I thought that his goal was to make
money for me. I was obviously wrong as his commissions grew while my net
worth dropped.
During the last three years, I have learned to spend time managing my
investments more closely and more safely as my net worth has climbed to nearly
$900,000. I don't have a broker and depend exclusively on information that is
publicly available. Please support Regulation FD.
Gregory A. Ray
I
Author: "Schuyler H. Richardson" at Internet
Date: 08/09/2000 9:47 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No.
------------------------------- Message Contents
This is to register my strong support for the proposed Fair Disclosure
regulation to be voted on today by the Commission. Please contact me if
you need further information to process this comment.
Schuyler H. Richardson
116 So. Jefferson St.
Huntsville, AL 35801
256-533-1421
shr@bellrich.com
Author: at Internet
Date: 08/09/2000 10:33 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
From:
Tomas Saez
84 pinewood Road
Hartsdale, NY 10530
Dear Madame/Sir,
As we have enter a new era of communications, clarity, should be the goal of
providing information. Companies "need" stop to favor a few and share with
the general public their information on an equal basis.
Obviously, the distribution of privileged information (it would be difficult
to stop it), as mostly occur today, with by invitation dinners at posh
Scottsdale, New York or Vail restaurants, or four hour rounds of golf in
Maui, in which a few would continue to exchange privilege information. As for
the masses, just to be a little near would be a step forward.
Good luck, it is needed it.
Tomas
Author: Marlene Satter at Internet
Date: 08/09/2000 10:43 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Please require that information be disseminated fairly to everyone, not just
analysts.
Individual stockholders have a right to information to make informed
decisions, and
they should not have to wait in line for that information if they are not
wealthy
stockholders being fed information by analysts at brokerage houses.
Individual investors who manage their own portolios and do not have analysts
at their
beck and call are far more likely to be negatively affected by information
released only
to analysts (and then to wealthy investors). They will have to wait to see
the price
move on their stocks before they can act, because they will not be privy to
information
that the wealthy get as a matter of course. This will lower the amount of
money they
can make in the market and increase the possible losses they will incur. It
is very
unfair for the wealthy to get their information first.
I am a stockholder and am far from wealthy. But I feel that I should have
the right to
know pertinent facts about the companies whose stock I own, or whose stock I
am
considering buying, at the same time as those who have a lot more money than
I do. I
make my own decisions concerning what goes into my portfolio, and I do not
rely on
analysts' opinions. But I would make better-informed decisions if I were
privy to the
information they receive as a matter of course.
Please vote on the side of democracy and fairness. Pass this regulation to
require full
disclosure and end selective disclosure. Thank you.
Marlene Y. Satter
Author: Patrick Serpas at Internet
Date: 08/09/2000 5:37 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
Dear Sir or Madam:
Please vote Thursday to pass Regulation FD to prohibit companies from
passing material market-moving information on to favored Wall Street
analysts without simultaneously making the information available to the
public at large.
Thank you,
Patrick Serpas
1340 E. Clower St.
Bartow, FL 33830-7237
863-533-2812
Author: Brian C Sisk at Internet
Date: 08/09/2000 8:52 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. 57-31-99
------------------------------- Message Contents
To whom it may concern,
Believe it or not, a lot of us individual investors, particularly the ones
that would be interested in timely company disclosures, are very capable of
managing our own finances. Not all of us are a bunch of idiotic day-traders
who buy and sell on a whim. In fact, it is the day traders who likely don't
have time to use this information if they are trading constantly.
Some in Wall Street have contended that we might be 'confused' by 'information
overload' if we have more disclosure. This is ludicrous. Count the letters
and emails you have gotten from individual investors who are fearful of all
this information. Those who can't handle it won't seek it.
Finally, and most sickeningly, Wall Street has contended that we can't be
trusted with our own money, as we are sure to lose it. First, it's my money
and I have the right to do whatever I like with it. Second, if anyone is
likely to lose money, it is the 90% of mutual fund managers that regularly
underperform the market. And they say that we're not to be trusted! I can
beat their returns with an index fund.
Please vote for the pending rule. The only thing that we have to fear is
lower commissions, higher returns, and financial freedom. The only thing that
Wall Street types have to fear is their jobs. Maybe that's why they've been
so vociferous on this debate.
Brian Sisk
Western Kentucky University
Author: Paul Swaekauski at Internet
Date: 08/09/2000 8:13 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: proposed Regulation FD (Fair Disclosure)
------------------------------- Message Contents
Sirs,
I am a small investor and part of a stock club and communication
group which follows the market and are internet saavy.
Please consider that we are fully in support of this rule which will allow
information to be provided publicly at the same time that Wall Street
Analysts obtain company information.
Having access to this information at the time of disclosure levels
the playing field for all investors, providing all the same
opportunities. This is the hallmark of a free-market system.
thank you,
Paul Swaekauski
Paul Swaekauski
Operations Program Director for Globalstar Plus Programs
Author: Sumeet Valrani at Internet
Date: 08/09/2000 6:41 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Re: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
My name is Sumeet Valrani
> Subject: Proposed Regulation FD: File No. S7-31-99
> Author: Sumeet Valrani at Internet
> Date: 08/08/2000 8:31 PM
>
> Proposed Regulation FD: File No. S7-31-99
>
> vote yes
>
>
>
Author: at Internet
Date: 08/09/2000 8:52 AM
Normal
TO: RULE-COMMENTS at 03SEC
CC: RMcConkey@BDBC.com at Internet
CC: BSales@rsac.com at Internet
CC: MVaughan@DeRoyal.com at Internet
CC: VGH579@cs.com at Internet
CC: HanWilPR@aol.com at Internet
CC: MaxRamsey555@cs.com at Internet
CC: Rankin@USIT.net at Internet
CC: Michelle.Dove@JAKing.com at Internet
CC: AKorte@usit.net at Internet
CC: KellyPowers712@cs.com at Internet
CC: RheaDan@msn.com at Internet
CC: RonnieS@Cone.com at Internet
Subject: "Proposed Regulation FD: file No. S7-31-99"
------------------------------- Message Contents
To: The Securities and Exchange Commission
I am asking that you change the rules and that companies be prohibited from
passing market information through favored Wall Street analysts. It is only
fair that the public be given equal and timely access. To much is added or
taken away from what is released and to many opinions are added that are not
what the company released when released through analysts. There are to many
self serving conflicts of interest for the analysts, brokers and advisors to
pass on unbiased, fair and complete information to buyers and sellers.
I can't imagine that there is even a debatable issue here. What you have to
do should not be based on who and how many people and how much money is
spent on lobbying for or against the rules but rather what is ethically fair
and morally right. If the truth could be known there have been billions of
dollars lost by the individual investors who to trusted the information that
their trusted broker or financial advisor sold them, earning a commission,
only to ultimately find out that they did not have a chance to make any
gains from the transaction either because the broker or advisor did not know
any better or because he or she was blinded by commissions or required by
the corporate order of his employer to meet certain objectives even at the
expense of the individual.
I know this to be factually correct. I have been there and have experienced
it. It is as wrong as robbing a bank and I think worse. Robbery is a
straight forward action whereas this is a hidden, enhanced, covered up,
misrepresented and advertised action of theft.
Please do your job. Require companies to disclose information to the public
at the same time that Wall Street gets the information. Individuals will
still have the choice to listen or not and still use the analyst
interpretation if they choose. As least give us a choice.
Jim Vaughan
7805 Ember Crest Tr.
Knoxville, TN. 37938
865-922-3017H
865-549-5724 B
Author: at Internet
Date: 08/09/2000 7:06 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Selective disclosure
------------------------------- Message Contents
Subject: Proposed Regulation FD: File No. S7-31-99
Selective disclosure is just plain wrong.
If there is any valid reasons for this, I cannot see it and have not heard of
it.
Jon R Wagner
Pensacola, FL
Author: "Woll; Jeff" at Internet
Date: 08/09/2000 10:22 AM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I believe individual investors should have access to the same corporate
information as companies provide to stock analysts--and at the same time. I
recommend voting in favor of this regulation.
Regards,
Jeff Woll
Private investor
http://www.sec.gov/rules/0809b01.htm