Subject: Proposed Regulation FD: File No. S7-31-99

Date:    08/09/2000 7:47 AM
     
     
I've read all the documentation about this rule, and I've read the comments from
some the major analyst firms to this rule. I don't usually comment on public 
matters but as a (small) financial advisor, my thoughts are as follows:
  1.. If it is significant news, it should be disclosed equally - if nothing
else posted on a web site at the same time an analyst is informed. Yes there is 
a lot of fear, uncertainty, doubt (FUD) as to how the rule should be worded in 
order to avoid undue restrictions on a company but at the end of the day all 
participants know what is meant by material information (if nothing else it 
forms the basis of Insider Trading statutes). All that is required is for a form
of words to ensure that when the company is giving information with a view to 
affecting its price; then all must be informed
  2.. One of the major advantages of the US, and a reason I look there for
companies in the first place, is the availability of information, why restrict 
it?
  3.. If the major investment houses are so worried that it will reduce the
proper information flowing out to the street; then why are there so few "Sell" 
recommendations on the major stocks? Or should there be guidance for the less 
informed investor to distinguish between hold, buy, outperform, accumulate, 
strong buy, long term accumulate etc
  4.. If the "value-added" by the major investment houses is significant, then
their reports will still be read - if nothing else this rule will require (by 
nature of competition) investment houses to ensure that their analyst reports 
are factual and clear.
  5.. The rule is about disclosure of material facts. Nothing (quite rightly)
has been said about the analysis and weighting of those facts, that is a job for
the investor or the professional analyst. Caveat Emptor. Make the risks clear 
and make it clear that inexperienced users should read a Investment House 
analyst report, but if not.... Don't hold their hands, just make sure the risks 
are well understood.
  6.. Finally I find the argument that professional analysts must review stocks
to be somewhat specious - if nothing else it reminds me of the argument that 
allowing individuals to buy and trade stocks will be damaging to their wealth 
and therefore internet broking should be disallowed. Yes, there are risks in 
life and yes some stocks are (in my opinion) well over valued - but still 
subject to strong buys from some of the major investment houses - but that is 
the distinguishing feature between analysis and gambling
I realise that this submission is late, but in view of the comments made in the 
WSJ, I feel that I should say something
     
Thank you
     
---------------------------------
Henry Bremridge
8 Rue D'Artois
75008 Paris
France