Date:    03/21/2000  10:07 PM

Subject: IRI ON PROPOSED REGULATION FD

My name is Gayle Essary, and I am Executive Director of the non-profit 
Investors Research Institute, Inc., (IRI) whose website is located at 
http://www.investrend.com , which administers IRI.
     
Over the past two years, IRI has had a Task Force on Disclosure whose 
members have considered and held public hearings on a form of 
institutionalized Selective Disclosure which the Commission needs to 
consider in its rule-making deliberations.
     
This practice is so routine and ingrained that the investing and trading 
public itself is not aware of market forces which put the individual 
investor at a rank disadvantage to brokerages, money managers and 
institutions.
     
Simply put, press releases issued by public companies are inexplicably 
withheld from the public for 15 minutes while selected media, such as the 
Dow Jones, Reuters, CBS Marketwatch, Bloomberg and others, under the "guise" 
of "disclosure points", exploit the information by making bulletins and 
headlines available to their highest paying customers, usually brokerages, 
money managers and institutions, whose traders then buy or sell as much as 
fifteen minutes ahead of individual investors who become privy to that 
information only when the news distributors, PR Newswire, principally, and 
BusinessWire then release the same information to the public. 
     
The public information is deliberately withheld from the broader public 
distributors, such as Comtex, NewsAlert, Individual, Wavo, NewsEdge and 
others while their competitors and their competitors' higher paying 
customers continue to be advantaged by this egregiously improper selective 
disclosure.
     
When questioned, the agencies responsible for this state that "we are 
following the SEC mandate on disclosure".
     
As part of the Task Force's work, our staff has discussed this with high 
ranking authorities at the NASD and the SEC and have been informed that no 
such SEC or NASD policy exists which permits such selective disclosure.
     
As part of this rule making, we urgently suggest that the SEC clarify this 
matter, close this loophole, if one exists, and instead mandate that public 
company press releases be made available to all of the public at the same 
time.
     
Thank you.
     
Gayle Essary
Executive Director
Investors Research Institute, Inc.
P.O. 750471
Forest Hills, NY 11375-0471