Subject: File No. S7-31-99, Support of Immediate Implementation of Re

Date:    08/07/2000 12:43 PM
     
     
     
Richard L. Berman
172 New Mark Esplanade
Rockville, Maryland 20850-2732
301-294-9235; 301-294-8056 fax
rberman@mindspring.com
Monday, August 07, 2000
     
Jonathan G. Katz
     
SEC Headquarters
450 Fifth Street, NW
Washington, DC 20549
     
     
Re: Support of Immediate Implementation of Regulation FD, File No. S7-31-99
     
Dear Sirs,
     
As an individual investor, I want to express my strong support for immediate 
implementation of Regulation FD. I realize that I have missed the official 
deadline for comments, but, if possible, I would like my comments to be on 
the record.
     
In the interest of fairness and efficient markets, it is important to have a 
level playing field on the dissemination of significant information about 
publicly traded companies. The public at large should have access to the 
same information as securities industry insiders. There is no excuse for any 
party getting information ahead of the public; indeed any trades made as the 
result of information not released to the public should be considered 
"insider trades".
     
I have often seen stock prices move in advance of public announcements and 
later found out that companies gave securities analysis a "head start". 
That's fundamentally unfair. It also leads to sweetheart arrangements where 
securities analysis go easy on companies in exchange for getting information 
before the public.
     
     
The prompt simultaneous release of information should in no way interfere 
with securities analysis doing their jobs. Securities analysts will just 
have to use their brains, not the privilege of prior access to information, 
to get better than average performance. Please don't let the SIA stall 
implementation of rule FD for their own selfish benefit, as the public's 
expense.
     
     
     
Yours truly,
     
     
     
Richard L. Berman