Date:    03/20/2000  10:48 PM

Subject: Selective Disclosure and Insider Trading Proposed Rule

Subject:  SECURITIES AND EXCHANGE COMMISSION, 17 CFR Parts 230, 240, 243, 
and 249, Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99, RIN 
3235-AH82, Selective Disclosure and Insider Trading
     
Three cheers to the SEC for bringing this subject to the light of day in 
spite of all the vested interest Wall Street brokerage opposition!  Of 
course, all the brokerages want is what is best for the average investor. 
Right!
     
What is the real point of "analyst expectations" anyway?  After all, 
analysts can never know as much as the company itself does, yet the 
companies are penalized if they "fail to meet analyst expectations."  It 
cannot be more clear that if the company's earnings differ from the "analyst 
expectations," then the analyst, not the company, is wrong!
     
It doesn't take a rocket scientist to figure out that "analyst 
expectations," resulting from priviliged meetings with company insiders, do 
nothing but add unnecessary roller-coaster volatility to the market quarter 
after quarter depending on whether companies "meet analyst expectations." 
This volatility DOES NOT help the average investor.  What it does do is 
allow the analyst's "expectation" to manipulate the stock price to benefit 
the analyst's brokerage and their best clients, whether the brokerage wants 
the price to go down to buy more or sell short, or go up to sell their 
position.
     
The privileged and protected illicit relationship of company insiders with 
analysts and their brokerages must end!
     
Bob Baird
Co-author of ELECTRONIC DAY TRADING TO WIN (John Wiley & Sons, 1999), and 
Co-creator of Brokersaurus.com