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Ownership Disclosure & Trading Restrictions

Updated February 25, 2013

 

Wyatt Investment Research

Disclosure Statement

 

Date Issued: February 25, 2013

 

This web site, published by Wyatt Investment Research LLC, is an investment newsletter advisory that is built on the premise of assisting individual investors in learning about investing. Our goal as publishers of financial information is to provide unbiased research and analysis of investments to our subscribers.

 

We strive to find rewarding investments for our subscribers, and in no way want that to be tarnished. An integral part of that effort is our disclosure policy.

 

Wyatt Investment Research encourages its employees and contributors to its publications (“covered persons”) to invest in individual stocks. We believe that in doing so, our employees and contributors to our publications are better able to understand the stock market and share this knowledge and share our experiences with subscribers. After all, who would want to join an investment newsletter where the employees never made their own investments?

 

Further, Wyatt Investment Research does permit its employees to invest in companies discussed within the newsletter. We have, however, put in place strict restrictions and disclosure policies in order to put the interests of our subscribers first and foremost.

 

Below you will find the details of this policy.

 

Disclosure 

 

Our full disclosure policy is designed to keep you fully aware of any stocks that are owned by covered persons and also discussed within our newsletters.

 

When we mention a company within an issue of a newsletter and a covered person owns the stock in an investment account they control (directly or indirectly), that position is fully disclosed.

 

All companies covered within the newsletter and whose securities are also owned by covered persons are listed at the bottom of each issue or article in the Disclaimer.

 

Trading Restrictions 

 

In addition to full disclosure, we have also developed trading restrictions which apply to all covered persons. These restrictions apply to stocks covered within newsletters published by Wyatt Investment Research (with the exception of $100k Portfolio and Options Advantage, where editor Ian Wyatt executes trades in his personal portfolio and shares those with subscribers).

 

  1. Once the editor, research analyst, or writers have decided to begin coverage of a new company, that company is placed on a "Restricted List" which bars trading in that company’s securities effectively immediately, and for two full trading days after the date of the publishing of that article. Covered persons must disclose any positions in companies on the Restricted List immediately. 
     
  2. In the event that covered persons do own shares, WIR will not publish an initial report on a company until five trading days have passed from the date of the most recent transaction, and the fact of such ownership will be disclosed. 
     
  3. Covered persons cannot buy or sell shares for two days after the issuance of an initial report on a company. Since many companies are mentioned regularly in update issues or alerts, this restriction only applies to initial research reports to purchase a company, and subsequent recommendations to sell a company.
     
  4. "Tipping" non-employees in advance of a report that will be written about a specific company is strictly forbidden, as is the use of third parties to circumvent our company’s policies. 

 

Compensation

 

Wyatt Investment Research generates revenues from advertising in our free publications, and subscriptions to our paid subscription investment newsletters. 

 

Wyatt Investment Research is a publisher of independent newsletter services, and does not receive compensation in exchange for writing articles about stocks in the regular issues of our publications. Our publications do send third party advertisements, with proper disclosures to tell recipients that these are in fact advertisements. 

 

We do sell advertising to other companies including brokerage firms, web sites, publicly traded issuers, investor relations firms, and investment publications, among others. Wyatt Investment Research makes no warranty as to the policies of these organizations, and in no way endorses their offers, services, or the content of their advertisements.

 

When an advertiser is a publicly traded company or a third party acting on behalf of a public company, we fully disclose all compensation in the email advertisement. Such disclosure is included in a disclosure statement in each of the advertisements sent via email.