Letters Released June 12-23:	Date:	Position:
Bond Market Ass'n.	6/22/00	This association urges the SEC to keep certain key objectives in mind: flexibility, enhanced access to information, elimination of artificial distinctions between firms offering comparable services, and consistency of regulations. Specifically, BMA supports an access-equals-delivery model, believes that an issuer is not responsible for all hyperlinked information, and does not support the republication requirement.
Union Central Life Insurance Co.	6/20/00	The assistant counsel to this life insurance company states her concern that electronic signatures may lead to unqualified organizations selling variable annuities online. In addition, she believes that a notice stating on what date an investor should check a Web site for information is sufficient notification. She is also against any penalties or fees associated with an investor's request for a paper copy of information offered electronically.
Council of Intrastructure Financing Authorities	6/19/00	The council opposes the suggested republication requirement, anticipating that it would discourage issuers from utilizing electronic media. It also opposes the suggestion that information posted on Web sites might be considered to be part of the disclosure documents furnished to investors, despite clear statements to the contrary. It is concerned that ambiguity about what information is considered to be part of a disclosure document would discourage the use of Web sites for disclosure and non-disclosure purposes alike.
Fidelity Investments	6/19/00	Fidelity Investments recommends that the SEC rethink its position related to hyperlinks, consider providing more flexibility in access to documents, reconsider issues of consent, provide guidance on how trade confirmations and prospectuses may be delivered together, clarify its position on the regulation of interactive discussion forums, and allow for electronic-only offerings.
Government Finance Officers Ass'n.	6/19/00	The GFOA believes that dissemination of disclosure information electronically is simply an alternative method of delivery and that, if the SEC wishes to encourage electronic disclosure, no new securities law liability should be associated with it. The association also rejects the republication requirement, believing that the obligation to update would have a chilling effect on the use of electronic media.
Investment Co. Institute	6/19/00	ICI believes that the SEC's new guidance serves to create barriers to a mutual fund's use of electronic media by not considering unique aspects of mutual funds and not providing any mutual fund-specific examples. For instance, the guidance on hyperlinks conflicts with the current NASD conduct rules applicable to mutual fund Web sites. ICI recommends that the SEC clarify that the issuer's responsibility for third-party information to which it establishes a hyperlink from a document required to be filed under the federal securities laws was not intended to cover hyperlinks from mutual fund advertisements.
Kutak Rock L.L.P.	6/19/00	This firm fully endorses the use of electronic media for disclosure purposes and supports the positions taken in the release, aside from the SEC's position on access to historical information.
Nat'l. Ass'n. of Bond Lawyers	6/19/00	This association is against the proposed republication requirement, believing that the necessity of updating posted disclosure information every time an investor goes to the Web site for that information puts an extra burden on those choosing to disclose electronically. Instead, information communicated electronically should be treated just like information communicated on paper as accurate as of a particular date.
Nat'l. Council of State Housing Agencies	6/19/00	The council supports the positions taken by the guidance regarding the consent to electronic delivery, the approval of PDF format and the responsibility of issuers regarding information included through hyperlinks. However, the council adamantly opposes the republication requirement.
Nat'l. Federation of Municipal Analysts	6/19/00	The federation states two primary concerns with the release. It is opposed to the republication requirement and the disclosing of information in an electronic-only format.
Davis, Fred Bunker	6/17/00	This individual investor believes that access does not equal delivery and that investors should be notified of all developments relevant to their investments. He also states that explicit consent for electronic delivery should be required.
Florida Division of Bond Finance	6/16/00	This governmental division believes that the SEC release introduces some troubling concepts and suggests that the SEC provide further guidance, especially regarding the concept of "republishing" information presented on a Web site each time the information is accessed by an investor. The Florida Division is against the republication requirement because it believes it will increase the governmental issuer's disclosure obligations and perhaps discourage issuers from using a Web site for disclosure purposes.