Wyatt Investment Research LLC
Trading Policies and Other Disclosures
Date Issued: November 12, 2019
Wyatt Investment Research LLC (“WIR” or “we”) publishes this website and related content (newsletters) to provide individual investors with investment education and to highlight investment opportunities. Our goal as publishers of financial information is to provide unbiased research and analysis of investments to our subscribers as well as general financial education.
We strive to find rewarding investments for our subscribers, and have aligned our internal policies with that goal. We believe in transparency with our readership and have set forth our policies below for all to view.
WIR 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 are better able to understand the stock market and to share that knowledge and our experiences with subscribers. After all, who would want to join an investment newsletter where the employees never made their own investments?
More so, we permit our covered persons to invest in the specific stocks recommended on the website and in our newsletters. We believe that an employee’s demonstrated commitment to a position, whether it turns out to be successful or not, shows “skin in the game” and can sharpen insights for our subscribers.
We hold our employees to the highest standards of integrity. Accordingly, we have put in place disclosure and trading policies so that our subscribers are treated fairly. Below you will find the details of those policies.
WIR has a disclosure policy designed to ensure full transparency relating to covered person holdings of securities referenced in our publications. Specifically, when we mention a company within a newsletter and a covered person owns the stock in an investment account they control (directly or indirectly), that position is fully disclosed at the end of the newsletter. This includes direct and beneficial share ownership.
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 WIR. The restrictions are as follows:
- Stocks on Restricted List: Once the editor, a 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, effective immediately.
- Pre-existing Holdings: Covered persons must immediately disclose any positions in companies on the Restricted List to our Trading Compliance Officer. In the event that a covered person already owns shares of a company placed on the Restricted List, WIR will not publish an initial report on a company until at least five (5) trading days have passed from the date of the most recent transaction, and the fact of such ownership will be disclosed.
- Two-Day “No-Transact” Period: Covered persons cannot buy or sell shares of a company placed on the Restricted list until at least two (2) trading days have passed since the issuance of an initial report on a company. Because 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.
- Ongoing Notification Obligation: Covered persons must disclose all transactions in the securities of companies on the Restricted List to Trading Compliance Officer on an ongoing basis.
- “Tipping” Prohibited: Covered persons may not “tip” any non-covered person (g., a family member, friend, spouse) about any security or company on the Restricted List. Tipping occurs when a covered person provides material, non-public information about a security or company on the Restricted List. For example, covered persons may not inform non-covered persons about an upcoming publication relating to a stock before the publication is published.
Wyatt Investment Research is a publisher of independent newsletter services that relies primarily on subscription revenue for its income. WIR may also receive advertising revenue and indirect benefits from third parties in connection with its business.
For example, from time to time, WIR may include third-party advertisements in its newsletters and/or on its website. WIR requires advertisers to clearly identify such content as paid advertising and in no way endorses their offers, services, or the content of their advertisements. Advertisers on WIR may include brokerage firms, investor relations firms, and investment publications, among others.
Advertisers may make their own, completely separate recommendations to buy or sell securities, some of which may include securities recommended by WIR to its readership. WIR has no knowledge of those recommendations and those recommendations have no impact on WIR’s independent analysis of the companies it recommends (or does not recommend) and WIR makes no representations or warranties as to other entities’ recommendations. Further, to the extent that advertisers are entities regulated by the SEC or FINRA, those entities may have their own disclosure documents for which they are solely responsible. WIR in no way warrants the policies or practices of those organizations.
Finally, in some instances, a publicly traded company may request permission to distribute a WIR report about the company to the company’s shareholders and prospective investors. In return, the company may agree to share contact information (as permitted by law only) with WIR. That information may permit WIR to target potential newsletter subscribers. WIR does not receive any direct compensation from the company and does not pay a referral fee for that information. However, such an arrangement creates a conflict of interest for WIR, which it is fully disclosing here.
We have designed our trading guidelines and disclosure policies to serve our investing community, our customers and our employees fairly. As always, however, you should perform your own due diligence about each investment you plan to make and consider a wide array of information about that investment outside of our publications. You may also want to consult with your own trusted financial professionals for personalized advice.