Date:    04/20/2000  6:42 PM

Subject: The SIA's filing

"...it hardly needs saying that analysts perform a necessary and valuable 
function in the U.S. capital markets" 
List them. What can they do that I couldn't do just as well for myself, given 
the same information at the same time? Nothing. This proposal will not make 
analysts obsolete, it will just force them to create value rather than 
regurgitating priveliged information.  Many people will still rely on 
analysts, but with the proposal, the analysts will be more accountable. 
     
"... 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."
Why is this not realistic? Who says I can't understand these prospectuses? 
Some analyst with half my intellegence and twice my training? Please. The 
idea that this sentence so thoroughly dismisses as absurd is a fantastic 
idea: everyone fully informed about the state of their investments. This is 
only uncomfortable for analyts who have a vested interest in the status quo 
and in taking advantage of their less-informed clients. Why does full 
disclosure scare them so much? If individual investors are as stupid as this 
comment suggests, full disclosure would have no effect on their client base 
at all; the clients would simply ignore the availible information and rely 
on the analysts just as they do now. Perhaps they are worried about an 
informed populace making them obsolete? Wasn't this the same reason Southern 
slave-owners had for making it illegal to teach their slaves to read? An 
ignorant populace is a pliant populace.
     
"Analysts make the markets less volatile"
Analysts are the prime contributors to volatility. If it weren't for analyts 
giving their moment by moment recommendations and encouraging short-term 
trading, volatility would be much lower. Brokers have much to gain from 
volatility because each trade is a commission, and the more volatility in 
the market, the more trades are transacted. Therefore: Volatility = 
Commissions for brokers and wasted money for investors. It is exactly this 
sort of conflict of interest that this full disclosure rule would mitigate.
     
"Analysts spend much of their time ferreting out negative information about 
companies"
This is as good as saying "Analysts spend much of their time slanting 
information to create market volatility." This is preposterous.
     
     
In closing, what do individual investors gain from full disclosure? Fair 
disclosure of information preventing analysts from  taking unfair advantage 
of the fact that they get information before the general public. Less money 
wasted on brokerage fees. Money saved at tax time due to fewer trades. 
Useful, timely information.
     
What do individual investors lose? The opportunity to be talked down to by 
arrogant analysts telling them they are too stupid to invest their own 
money. No thanks.
     
What do analysts gain from full disclosure? Nothing.
     
What do analysts lose? Prior information. Brokerage fees.  The opportunity 
to slant information they present. The donuts from those private meetings 
with CEOs. 
     
     
Mark Owens