Date:    03/16/2000  2:25 PM

Subject: Selective Disclosure and Insider Trading - S7-31-99

I would like to express my opinion as being in favor of the SEC's proposed 
new rules under file number S7-31-99.
     
I have 32 years of experience with the securities industry. The last 5 as a 
registered financial advisor. Prior to that, as registered representative, 
and branch manager for major NYSE member firms.
     
     
The practice of selective disclosure today is in my opinion a major cause of 
the volatility in the stock market. When brokerage house analysts can listen 
in on conference calls from major public held companies, hearing information 
that will most likely influence the company's stock price, and then 
immediately call their large institutional clients, so they can effect 
transactions ahead of the general public, that borders on a criminal act.
     
Case in point, Barron's reported in their September 21, 1998 (NW5), that 
Gillette held an early morning conference call with a selected group, to 
give them information about weakness in sales levels. The Barron's reported 
that the analyst from at least one major brokerage firm immediately relayed 
the information to selective clients. Almost as soon as the market opened, 
Gillette's stock went into a free fall, much greater than usually volume. 
Clearly, this was not the public placing the sell orders. However, the 
buyers probably were many many individual investors, who did not know that 
the seller likely had material information negative to the Gillette's bottom 
line. Not until late in the day, did Gillette make a public statement which 
included their thought that they did not think the information was material. 
The facts of the day's trading proved pretty clearly that they were wrong in 
that opinion.
     
     
Today, we have a new kind of stock market. A great number of investors are 
using mutual funds to invest. A very small number of decision makers are 
making transactions in hundreds of thousands of shares per trade. Getting 
selective information to these relatively small number of decision makers is 
causing explosive actions in the markets. It is totally wrong - probably 
criminally. It needs to be stopped. Publicly held companies can today 
communicate with the majority of investors quickly - e-mail, fax, releases 
to the media. No excuses should be acceptable.
     
New rules are needed. This unfair situation has cheated the public, and 
enriched a very small number of beneficiaries too long.
     
Much appreciation for the efforts of the Securites and Exchange Commission, 
and Chairman Arthur Levitt.
     
James A. Pagliaro
1128 Ridgeway Road
LaFayette, Ga. 30728