Public communication shall include any notice, circular, letter, email or other written communication (including any social media communications, online blog, video, or any other internet communication) addressed to more than one person, or any notice or other announcement in any publication or online media.

Firm Policy

The firm’s CCO shall be responsible for reviewing company public communication and ensuring it is in compliance with jurisdictional regulations. The firm CCO reserves the right to request any post be removed if it is determined to violate the firm's communication policy. In the event of any subjectively grey area, we should err on the side of caution.

Compliance Requirements

Public communication may not:

• Use or refer to testimonials (which include any statement of a client's experience or endorsement)
• Mislead clients using misrepresentations or exaggerations
• Contain possibly misleading use of superlatives (ie: always, never, definitely, guaranteed)
• Refer to past, specific recommendations made by the adviser
• Represent that any report, analysis, or other service will be provided without charge unless the report, analysis or other service will be provided without any obligation whatsoever

Additionally, the compliance officer will verify that no public communication contains any of the following:

• Representations that the communication was approved by a securities regulator
• Representations that the firm has been sponsored, approved, or recommended by any securities regulator. This does not prohibit a firm from stating that they are a registered investment adviser as long as nothing in the statement is otherwise misleading
• The initials “RIA” or “IAR” may not be used as they may be confused with a professional designation
• Any analysis, report, or publication concerning securities, or which is to be used in making any determination as to when to buy or sell any security, or which security to buy or sell
• Any graph, chart, formula, or other device to be used in making any determination as to when to buy or sell any security, or which security to buy or sell
• Any other specific recommendations with regard to securities
• Performance advertising is prohibited