Comments on Proposed Rule:
Selective Disclosure and Insider Trading
Release Nos. 33-7787, 34-42259, IC-24209, File No. S7-31-99
Author: David Bechtel at Internet
Date: 04/20/2000 9:24 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I find it difficult to believe that anyone would see any
rationality in the fact that a few select individuals should
receive inside information about an equity prior to a public
announcement. This existing set-up leaves the entire market
open to manipulation by a few, with inside information.
Many individual investors already feel that our equity
markets are controlled by "manipulators" or is in "stong
hands", as some might say).
Why should we believe an analyst anyway ? We are never sure
of their motives for whatever they may recommend, most
certainly, their main concern is themselves, as it is with
all of us. I've not that familiar with many correct
predicitions by any analyst, a correct prediction by an
analyst is about as rare as scoring a touchdown in the NFL.
Score a touchdown in the NFL and the player acts as though it
is the first one he has ever scored, the 2 or 3 analysts
who've made a correct predicition is on every TV station for
the rest of their life, their claim to fame - predicitng the
1987 market crash BEFORE it happened. These analyst spend
most of their time collecting private inside information,
then making their own investment decisions, then advise their
larger clients on this insider information to invest quick,
before the public finds out.
I see the role of analysts and business reporters as follows
-
1. Scare the public into selling, thus driving the equity
price lower.
2. Once equity price is down, then the "manipulators" buy.
3. After a little time passes, let out a little bit of good
news about the equity.
4. Wait for the public to buy, after short upward price
movement
5. Let out more bad reports about equity or again scare the
public to sell, sometimes called final shakeout.
6. Equity prices drops again as public gets scared and
sells way too soon
7. "Manipulators", "insiders", "strong hands" really buy
now
8. Usually a long quiet period follows this "final
shakeout"
9. Suddenly, for no apparent reason the equity's price
start to rise, sometimes dramatically
10. Public see equity rise, get excited, buy at too high a
price level
11. "Manipulators" sell at new high prices, equity drops
like a rock, with the public holding the bag.
Sounds like great plan for the select few who now are able
to participate in insider information, but it is a very bad
plan for the uninformed public.
Are the "manipulators" really trying to convince the SEC
that the public doesn't understand what it reads, but that
analysts are the only folks that can deciphor what the
equity's management is discussing. What a bunch of b.s. -
get a life, get real.
I was born at night, it just wasn't LAST NIGHT.........
David Bechtel
No company association
I believe in myself and my abilities
I make my own investment decisions
I make my own trades (Internet)
I believe in LTBH (Long Term Buy & Hold)
I only half believe what an equity analyst has to say
I never believe what LAWYERS OR NEWS REPORTERS say
Most of the time, I don't believe my government officials
Author: Henry Berendt at Internet
Date: 04/20/2000 10:01 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I dearly hope that the Securities and Exchange Commission will keep to
the sipirt of "free and equal markets" and support/endorse/implement all
requirements for fair and equal disclosure of information for publicly
traded companies.
There is nothing quite as strong preventing investment as knowing that
you, as an individual, cannot compete fairly and equally in the
marketplace with all comers.
I cannot accept the premise that those whose primary livelyhood is
investing for others should have a right granted to them by the
government to be privy to information concerning public corporations
that I, a private citizen, cannot obtain in a timely manner.
Please keep the markets free and open.
Thank You,
Henry A. Berendt
Kentfield, California
hberendt@marinternet.com
Author: at Internet
Date: 04/20/2000 11:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File #S7-31-99
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I strongly believe that the statements made by the SIA are self serving
and designed to maintain the status quo. I have heard no factual
presentation showing that what they claim is true. How can the
dissemination of information to all interested parties at the same time
be bad for individual investors? It can only be bad for those currently
privileged enough to get it first since they would no longer be in a
position of power or influence. It is about time the individual investor
got a break. Free up the information reporting structure. The financial
media will not cease to report the data just because they did not
receive it as an exclusive release. Maybe this will force the analysts
to return to objectively analyzing the companies instead of attempting
to be super star stock pickers.
Howard Blower
Individual Investor
Author: "Kevin Boyer" at Internet
Date: 04/20/2000 10:41 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To whom it may concern:
It is my belief that a 'level' playing field (companies releasing information to
general public, not just analysts) will actually benefit the marketplace. I
have been an individual investor for about 5 years now and believe that analysts
are in a position to sway the marketplace (and hence increase market volatility)
and sometimes manipulate stocks.
It is very difficult for individual investors to get access to the information
the analysts dribble out to the public and difficult to validate. In some
respects the 'practice of discreetly disclosing important information to Wall
Street analysts' gives them great power to hold investors captive to their
services.
The fact that one does not have to look too far to find analysts with
conflicting comments about the same subject hardly seems to support the SIA
claims that individual investors would reach the wrong conclusions regarding
investment decisions without their guidance.
In addition, most companies have their shareholders to keep them honest (i.e.
'spun' financial information can open them to shareholder class-action suits);
they (the companies) hardly need the analysts to make sure the financial
reporting is presented properly.
And last, individual investor confidence in the integrity of the marketplace is
far more likely to smooth market volatility. In fact, some of the wild swings
in the market place these past few weeks have been reported to be to a large
extent the result of institutional investment activity. The trading volume
seems to support this theory.
I hope this agency will strive to do what is best for all, and not be bound to
'old economy' thinking in an era where the individual investor is rapidly
becoming an important player in the marketplace.
Thank you for your interest in this matter.
Kevin Boyer
P.O. Box 246685
Sacramento, CA 95824
Author: "Randolph Buhlman" at Internet
Date: 04/20/2000 11:02 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs:
Selective disclosure is wrong and certainly a disservice to the investor. How
can one sincerely argue otherwise? Releasing public information to the public
simultaneously with analysts is the proposed model and should be implemented.
Yours truly,
Randolph Buhlman
Author: "JCB" at Internet
Date: 04/20/2000 9:27 PM
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TO: RULE-COMMENTS at 03SEC
Subject: "Proposed Regulation FD: File No. S7-31-99"
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Gentlemen,
I have read your recent comments regarding allowing information to flow
first to analysts who can interpret them appropriately for the lower
classes. Really, we need to protect the ignorant masses from themselves for
after all, soon they will be demanding equal access to other types of
information which could seriously upset the profits of the long established
companies. These big brokers and the like have worked hard to establish the
cash cow they have been enjoying.
Let's face it. There is only so much information the average person can
really digest or synopsize. If the only issue was inaccurate analysis, I
would still agree with the Security Exchange Commission (SEC). It is
thoughtful that the SEC is visionary, in recognizing that the bumbling
investor may lose his or her money based on the misinterpretation of a 10k
report; and, worse yet, have it affect them in other ways--like their social
life--by not being able to afford high-maintenance women.
Soon, if these minor pieces of information are allowed to get in the hands
of those unable to interpret them, the control of the market will
definitely shift. It may even have unpredictable swings--not the steady and
predictable moves of clear analysis. What would happen next? Heavens,
many of these long enjoyed profits may wind up with the likes of your
average astute investor and worse even yet, those individual greedy-types
called day traders who put all that avarice, liquidity and arbitrage into
the market.
Thank goodness for all the negative information these analysts ferret out
about these companies with their positive regard for fellow average
investors, and amazingly, without any personal motivation to enhance their
own portfolios as far as timing and self-aggrandizement is concerned. How
can they do this? They are after all, an elite educated group, in positions
of importance. They are self and SEC designated denizens to promote the
public welfare and promulgate good. You have shown great introspection in
your decision. I believe you have ruled on what you believe. Your
education and experience has probably been in the realm of unending zero-sum
games. I say ignore breakthrough thinking, the deduction and induction
processes, and the change promulgators. Stand tall, inveterate, poised to
protect tradition and avoid circumspection.
As far as those who say, "This is the biggest bunch of unmitigated bullshit
I ever heard of," I say now, now, that is precisely the inept analysis the
SEC is talking about.
Respectfully,
John C. Burke
Day Trader
Bull Moose Market Marauder
Author: "Shawn & Jennifer Clark" at Internet
Date: 04/20/2000 11:56 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I would like to contribute my comments on proposed regulation FD: File No.
S7-31-99
I am strongly in favor of the proposal to prevent discreet disclosure by
company officers to analysts. There are several important principles here.
The first is that such disclosure appears be inside information. In fact,
were it provided to me personally and I traded or recommended trades based
on it, then I believe it would be classified as inside information in
violation of the law. If the market as a whole is not privy to this
information, then it is granting an unfair advantage to the recipient
analyst and his/her employer and investors.
Secondly, the recent/rapid expansion and improvements in communication
technology make it practical for companies to release this information to
the general public. This can be done without preventing analysts from
performing their duties. Transcripts, summaries, or other such information
could easily be made available through electronic means. Initially, during
early implementation, the rule may indeed limit some disclosure by
corporate officers as they sort out how to conduct business in compliance
with the rule. History teaches us that, eventually, the market will adapt
and we will all wonder why discreet disclosure was ever permitted in the
first place.
Finally, I reject the Securities Industry Association (SIA) assertions that
this will substantially inhibit them from performing a useful public (and
private) service. I can find no reason that the information provided to
analysts could not also be revealed to the general public. Smart corporate
officers reveal information as needed now to prevent market shock. Should
the rules change, they will find new ways to accomplish the same thing, but
the size of the audience will change. Analysts will still retain
tremendous advantages over the individual investor: sophisticated market
models, reams of financial data, experience, training, and direct contact
with corporate officers (allowing them to ask their own questions, see more
and thereby glean a fuller picture than available through printed word or
video footage). What they will lose is unfair access to relevant corporate
information that should either be made public or not disclosed at all.
Also, contrary to what the SIA has stated, some individual investors (such
as myself) do read the company prospectus, research the company in print
and on the web, evaluate the market sector and the company's competitors.
We would benefit from having information revealed in a more timely and
public manner.
In summary, the strength of our nation and its markets is partly due to the
hunger for and access to information that we have as a society. This,
combined with a sense of fair play and free market capitalism makes our
economy the most powerful and advanced in the world. Implement the
proposed rule and help level the playing field for all investors.
Shawn Clark
Eastman Chemical Company
Longview, Texas
e-mail: sd&jkclark@tyler.net
Author: "Coombs" at Internet
Date: 04/20/2000 10:08 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. 57-31-99
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Gentlemen,
I am sending this e-mail to voice my opinion that all the information about
public companies should be shared with all of us at the same time rather than
protecting the large brokerage houses. I think that it is insulting for them to
argue that "they are doing this in our best interests". I think that analysts
for the most part, are biased, working for their own best interests and have
little concern for the rest of us. I strongly oppose their position on this
proposed regulation.
Sincerely,
Earl R. Coombs
Author: VictoriaD at Internet
Date: 04/20/2000 10:13 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: file No. s7-31-99
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As an individual investor, I feel the more information I can be given,
the better investment choices I can make. While it is true that
analysts as well as investment and brokerage firms provide important
services for investors, it is in my best interest to be as fully
informed as possible. As many analysts and firms work on commissions,
it is their best interest to control the information flow. This is in
direct opposition to my needs as an informed investor. The internet has
brought about a new world, and the rules are changing. It is time the
SEC acknowledged this by opening up information to everyone. I am much
more aware of my investments now that I take a more active role in
them. Knowledge is power. Empower people. Give them access to
information as soon as it becomes available. Trust that they will ask
questions (to the analysts and brokers!) if they don't understand
something.
Thank you,
Victoria M. Depaoli
Author: Phil Doherty at Internet
Date: 04/20/2000 11:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File # S7-31-99
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After applying several layers of bull hooey filters and utilizing my
"Captain Whizbang" secret decoder ring I have condensed the verbiage
to: (my apologizes to George Orwell) "Isn't it true that we are all
created equal"?, yes, "but some of us are more equal than others".
I, for one, am tired of the drivel that constantly flows from the
mouths of individuals who claim to know what is best for the "common
man". I am sure that Abby Cohen, Mark Mobius and their ilk must be very
satisfied with your frothing. I am reminded of an old country expression
that more than applies, Don't be "whizzing" down my back and then
telling me it is a warm spring rain......
Enough of the "Newspeak" bulletins from the Ministry of Truth.
Phil Doherty
phildo@alaska.net
Valdez, Alaska.
Author: Pat Flood at Internet
Date: 04/20/2000 11:49 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sir or Madam:
Regarding Proposed Regulation FD: File No. S7-31-99, I strongly support this
important and overdue rule.
Patrick M. Flood
pflood@yahoo.com
4019 Tazlina Ave.
Anchorage, AK 99517
---------------------------------
Do You Yahoo!?
Send online invitations with Yahoo! Invites.
Author: Keith Garner at Internet
Date: 04/20/2000 11:24 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I urge you to pass the regulation. Selective disclosure to "friendly"
anaylsts may well enrich the Wall Street firms, and even potentially
some of their favored clients, but it comes at the cost to the general
investing public. I see no justification for giving potentially
significant information selectively to Wall St. insiders so they can
move before the general public is informed.
While I am not surprised that the Securities Industry is opposed to the
rule, I disagree with their transparently self serving anaylsis of the
situation implying the general investing public is unable to figure out
the information, or read an annual report.
Again, I urge you to pass the rule as proposed.
Sincerely,
Keith Garner
an individual investor
Author: hagadorn at Internet
Date: 04/20/2000 10:57 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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To Whom It May Concern:
I am writing in support of the FD regulation. As a private investor, I
have personal experience with the pitfalls of relying on financial
professionals. I once had a full-service brokerage account and read
several financial publications; I now have a discount broker and do my
own research online -- and I have gone from dismally losing money to
outperforming the markets for the past three years. I would far rather
trust my own analysis than that of professionals, no matter how learned,
who may have conflicts of which I know nothing. Any regulation that
increases public access to market information is of benefit to me and to
the many small investors like myself.
Concerning the filing by the Securities Industry Association: their
comment that "it hardly needs saying that analysts perform a necessary
and very valuable function in the U.S. capital market....The alternative
model of millions of individual investors and potential investors poring
over prospectuses and periodic reports is highly theoretical and out of
sync with the real world" seems dubious. The first sentence does not
strike me as obvious; the second is offensive, and on reflection
alarming, too, as it suggests that the authors inhabit a different "real
world" than the one in which I and many other individual investors do
exactly those things, and quite well, thank you. The SIA's solicitude
is appreciated, but I don't need protection.
Very truly yours,
Susan Hagadorn, Ph.D.
Author: "Greg & Nancy Hutchings" at Internet
Date: 04/20/2000 8:56 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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How do these "experts" know that I'm not intelligent enough to make my own
informed decisions? From my perspective, my ability to make an informed
decision is hampered by the fact that I don't have access to the same
information at the same time. Surely millions of investors are already
making decisions without the aid of these "experts", yet still doing so with
valuable, publicly-available information. If making this information
available sooner is so dangerous, maybe you should create regulations to
force everyone to invest through a professional analyst for their own
protection. There is no reason we shouldn't have access to potentially
influential information before making important decisions. How can you think
for a minute that Wall Street analysts aren't fighting for their own
interests above all others?
Count me in favor of the proposed regulation.
Greg Hutchings
Author: Kamran Jazayeri at Internet
Date: 04/20/2000 11:28 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I, as an individual investor, fully support the elimination of the selective
disclosure rule.
Equal access to information for all market participants, large or small, is a
fundamental
requirement for healthy markets.
Sincerely,
Kamran Jazayeri.
Author: "Steve Kang" at Internet
Date: 04/20/2000 11:36 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs,
I feel that the Ad Hoc Working Group on Proposed Regulation FD and the Legal
and Compliance Division of the Securities Industry Association is way out of
line in its filing dated April 6th of this year. The whole thing smells of
analysts fearful of losing their "old boy" network. It makes some rather
insulting assumptions, including the following.
First the statement, "the ... model of ... investors poring over
prospectuses and periodic reports is highly theoretical and out of sync with
the real world" is quite disparaging. Who has more concern about whether my
money is invested in a good company, the analyst or me? The assumption that
no one other than analysts reads prospectuses is laughable.
Second, the filing claims that analysts' findings results in less
volatility. To this, let me give you an example. On March 30, Merrill
Lynch lowered its long-term rating on Amgen from "Buy" to "Accumulate."
Why? because Amgen is being sued by Transkaryotic Therapies, and Merrill
says that the trial, the outcome of which they are not willing to predict,
is likely to cause extreme volatility "over the next few months until Judge
Young hands down his final ruling." Hello? This is not creating extra
volatility? How do "next few months" and "long-term" relate to each other?
About as much as "analyst" and "less volatile" do.
Finally I question the claim that "it hardly needs saying that analysts
perform a necessary and valuable function in the U.S. capital markets." I
think that if it is true, it certainly does need some saying, because you'll
be hard pressed to convince me otherwise. What exactly do they do that is so
beneficial?
I hope that you take these into consideration, and I urge you to pass the
proposed regulation.
Sincerely,
Steve Kang
19080 Hayes
Castro Valley, CA
Author: "Rick & Teri Kessler" at Internet
Date: 04/20/2000 10:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File no. S7-31-99
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Ladies and Gentlemen:
Regarding the above referenced Proposed Reg. FD.
It is my opinion that to allow publicly traded companies to continue
disseminating any information regarding their companies to a select
"privileged" few (who may or may not be stockholders) does a disservice to
all stockholders in all publicly traded companies.
In the SIA's filing on April 6, 2000 in Section II C. ' Analysts'
Perspective ', the comment is made-"Leveling the playing field for analysts,
as among themselves and vis-a-vis the general public, will undermine the
great advantages of the current system."
Two queries on this statement;
1) The SIA freely admits the "playing field" is NOT level, so therefore
should not the SEC immediately institute Reg. FD so as to remove any unfair
advantage to these analysts and their brokerage houses?
2) To whom is the "current system" a "great advantage"? Certainly not to
"the general public."
I commend the SEC for recognizing the inequities inherent in the status quo
by proposing Regulation FD, and request its' passage and institution.
Regards,
John Richard Kessler
individual investor (who doesn't need talking heads treating him like a
lemming)
Member of the General Public
***************************************************
jrkessler@home.com
Author: "Larry Lim" at Internet
Date: 04/20/2000 11:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99"
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I am writing to support the above stated regulation for the following reasons:
a.. Firstly, analyst working for a particular investment house that
underwrites a certain company may be more reluctant to downgrade that company.
They may be in the position of conflict of interest. Information that may be
damaging to the company's stock may be withheld or de-emphasized.
b.. With the advent of internet, the advantage offered analysts has been
diminishing. The above rule will remove the last barrier to a level playing
field. This will enable well informed investors to better manage their own
portfolio. Accurate information is essential for good decision making. I wonder
SIA's opposition to this Regulation is based solely on fear that analysts role
in the the market will be greatly diminished with the removal of their
previously held unfair advantage.
c.. Sites like individual investors, Motley Fool now serves to educate the
public with their analysis without having any allegiance to a particular
company. They have taken on the role of analysts and are more likely to provide
unbiased opinion.
The argument by SIA that analyst reduces volatility is obviously untrue.
a.. Analyst often amplify market reaction to a particular news item by rushing
on mass to upgrade/downgrade the company involved. This certainly does not
reduce volatility. In fact analyst only encourage herd mentality as some
uninformed investor would just do what the sages say. Accurate information would
help alleviate this problem.
b.. As can be witnessed by recent turbulence in the stock market, a few
analysts commenting on their portfolio shifts irresponsibly triggered panic in
the market. The same analyst then reversed his/her stance after her initial
action affected the market thus giving him/her a chance to bargain hunt. This
clearly illustrates that analyst do not reduce volatility in the market but
sometimes causes them. One wonders if they have the individual investors' best
interest in mind.
c.. In another word, they have the power to influence the market in a
self-serving manner.
Larry Lim
Author: "victoria love" at Internet
Date: 04/20/2000 10:23 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File NO. S7-31-99
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Gentlepeople:
It alarms me that a debate exits over public dissemination of sophisticated
financial information for traded companies. That the SEC would consider analysts
more worthy by not requiring companies to fully disclosure financial information
simultaneously to individual investors is an affront to one of the most highly
educated, egalitarian and entrepreneurial populations in the world.
The argument that the average individual is unable to interpret all the data is
irrelevant since access, not capability, is the issue. The individual investor
who is interested will, in fact, create a means to understand, interpret, and
digest the material which is available. The truth in this statement is easily
visible and so obvious as to stir sincere concern about the mental acuity and
moral character of its proponents.
The idea that analysts make the market less volatile reeks of stale cigar smoke.
Any investor who has been left holding the proverbial bag after Wall Street's
elephants have stampeded would be happy to light such nonsense on fire and leave
it to be stomped out at the doorstep of such prideful profit-motivated
good-ol-boys who omnisciently deem themselves to know what is in our best
interest.
(By the way, If the SEC and the analysts know so much better than we what is in
our best interest, then obviously, they are working in the wrong area. These
omniscient benefactors should be urged to step in where countless others have
had little success. We could use substantive lectures on television violence,
censorship, gun control, and sexual abstinence.)
IF the SEC does not elect to have public companies disclose ALL information
simultaneously, it is doing all individual investors a much more than a grave
disservice.
Victoria Love
vlove@uswest.net
Author: Tony at Internet
Date: 04/20/2000 10:02 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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I disagree with the SIA, and believe I am intelligent enough
to make decisions about the value of securities. I do not
believe I need analysts protecting me from my own ignorance.
Tony Padua
Revenue Agent
IRS
Author: "John Phipps" at Internet
Date: 04/20/2000 10:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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Dear Sirs:
Please consider a level playing field for analyst and indivdual investor, pass
the proposed rule that will require equal disclosure for all involved.
John Phipps
Author: Andrew Rice at Internet
Date: 04/20/2000 9:58 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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4-20-00
To whom it may concern:
I am writing in support of the rule proposed by the Securities and
Exchange Commission (SEC) regarding the fair disclosure of information
by publicly traded companies to the public. This Proposed Regulation FD
would require, among other things, that companies no longer engage in
the practice of discreetly disclosing important information to Wall
Street analysts without also giving that information to the public at
large.
The Ad Hoc Working Group on Proposed Regulation FD and the Legal and
Compliance Division of the Securities Industry Association ("SIA") --
READ "principal lobbying organization for the full-service brokerages"
-- insults the many individual investor that make our countries equity
markets and free economy work.
Among the fallacies that they reported during the public comments of
April 6, 2000 concerning this rule:
* "We believe that communications between [a company] and individual
analysts or small groups of analysts contribute to the overall mix
of information in the marketplace . . ." Does this make any
sense? IN ESSENCE, "feed us special information at the expense of
the investors actually choosing to buy stock in these companies."
* "The alternative model of millions of individual investors and
potential investors poring over prospectuses and periodic reports
is highly theoretical and out of sync with the real world." This
is insulting. In an efficient market, the minimum standard should
be equal access to information, with those that want to rely solely
on analyst views being allowed to (sounds like a free market to
me). Remember, the brokerages would like us to make multiple buys
and sell blindly on their recommendation -- that's how they make
money!
* "The marketplace itself provides incentives for such diligence
(READ -- without this porposed rule, SEC sanctioned "insider
information"), for it is the analysts who get to the market
"firstest" with the "mostest" that under the current system reap
the reputational and financial rewards". In other words they
expect you to protect their business model -- keeping the
individual investor in the dark -- so they can make a profit.
INSTEAD, their business model should be modeled on the brokerages
ability to help the investor make better returns with their money.
Believe me, if their analyst can provide value added services, then
the investors will come to them, equal information or not! Let the
investors decide!
Please take the concerns of the individual investor seriously -- WE ARE
THE MARKET!
Andrew Rice
arice1@uswest.net
Author: "Mark Russell" at Internet
Date: 04/20/2000 11:03 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
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After reviewing the filing by the Securities Industry Association regarding
the above proposed regulation, I feel compelled to offer my comments on the
matter. As a knowledgeable and prudent individual investor who takes the
responsibility for researching my equity investments, I'm am insulted by the
SIA filing. While I expected protests from the brokerage industry, their
elitist attitude and condescending tone is somewhat of a surprise.
The SIA filing, in my opinion, provides even more impetus for the Securities
and Exchange Commission to pass the proposed regulations. This scandal of
allowing a self-described "elite few" early access to key information so
that they can use their "superior intellect" to maintain market balance is
outlandish. Do the right thing and pass these regulations!
R. Mark Russell, MD, MPH
Author: "John White" at Internet
Date: 04/20/2000 10:08 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I deserve the same access to data as any "analyst" and am quite prepared to do
my own due diligence.
If an analyst can convince me by their superior performance that they know how
to interpret the data more effectively than I, I would be prepared to pay for
their opinion, up to the value that it added for me. If they have to hide
behind closed doors to "prove" that they know better, it raises nothing but
suspicion of their intentions, and prevents me from seeing how much "better"
they are.
I certainly don't want to be "nannied" by people who are afraid to let me have
the same information advantage that they have. Level the playing field and lets
see who does better!
John White
Author: at Internet
Date: 04/20/2000 11:07 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
It is outrageous to allow anyone, especially analysts - the self-proclaimed
knowledge end-alls and manipulators of Wall Street - to have access to a
better-quality strata of information than what is available to the general
public.
I would pose the true motivator at play is money..the selfish fear that with the
public's ongoing trend of self sufficiency, analysts see their positions
becoming extinct as time goes on.
However, a less manipulated market, which does not swing violently upon the
words of a few (Abby Cohen), regardless of how innocent the intention may be,
should be a necessary goal for the SEC.
<<...>>
> *****************
>
Gray Williams
Gray Williams
Rhythms Alternate Channels
703.624.0966
Author: "Steven and Jane" at Internet
Date: 04/20/2000 10:03 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: Proposed Regulation FD: File No. S7-31-99
------------------------------- Message Contents
I am absolutely for passage of the above regulation.
Steven Wolfson
http://www.sec.gov/rules/0420b01s.htm