Author:  <DAllen@genre.com> 
Date:    03/21/2000  12:13 AM

Subject: S7-31-99

It is my opinion that this is a catch-22 situation for Wall Street. The 
louder they decry this the more I am sure that it is absolutely needed. I 
find it hard to believe that they are raising a self-less opinion. 
Information is quickly becoming their last bastion.
     
I would also suggest that companies reluctance regarding this disclosure is 
similar to that of the securities firm. If they can no longer use their 
investment bankers to spin information the way they want it might cramp 
their style. The company and their analysts seem tighter today than any 
other time in history. How often does the comany comment on an analyst 
report prior to it's release? And isn't a company that says it is 
comfortable with an analysts number simply announcing it's own projections? 
It would S7-31-99 would help eliminate some of these issues.
     
I have heard it suggested that individual investors are unable to 
understand the issues. If this is true then I guess we also need to re-work 
our legal system. Clearly jurors are unable to understand the issues. And 
certainly those same individuals ought not be able to vote as they can't 
understand the issues.
     
I would suggest that all information be not only immediately available but 
that it also be provided in plain English. The internet kills any argument 
that a firm might have regarding cost and ease of providing said 
information. In fact they could send automatic emails to their shareholders 
and other interested parties that have subscribed in the same way that 
vcall.com and other services seem able to do. The firms might even find it 
a great way to build a loyal shareholder base that understands their firm 
and is willing to hold it for the longrun. Not a mutual fund doing same 
window dressing at the end of the quarter.(Could you please tell me why 
window dressing is legal or permitted.)
     
I have noticed that firms quickly adopt to new rules and regulations once 
they understand them and understand that they must adopt.
     
It has taken some time for firms to adopt the safe harbor provisions of the 
Private Securities Litigation Reform Act of 1995 but enough of them have. 
Although I would suggest that many are using boiler plate language  which I 
hope that the courts will strike down as against the spirit of the law.  I 
would also suggest that Silicon Graphics decision needs to be re-considered 
as claims with merit are going to be dismissed. What would happen if 
Cendant didn 't make it past the motion to dismiss?
     
As respects insider trading the issue that I think truly needs to be dealt 
with is  timing of the disclosure of trading. Why shouldn't it be prior to 
the sale? Or at the latest, at the time of the sale? It would help the 
insider should plaintiffs bar file a securities class action suit to 
demonstrate that no nefarious reasons exist for  his purchase or sale. 
Again, the internet eliminates any argument regarding the cost and timing 
of disclosure.
     
Thank you for considering my opinions.