Disclosures and Details

Please read the following information carefully.

This document contains two distinct parts.

Part 1: DISCLOSURES ABOUT OUR BUSINESS contains critical information that will help you use our work appropriately and give you a far better understanding of how our business works — both the benefits it might offer you and the inevitable limitations of our products.

Part 2: PROMOTION DETAILS contains facts, figures, explanations, annotations, facts about testimonials, and other resources about the promotional piece you just viewed. If you have questions or want more information about the marketing material you just viewed, the first place to look is Part 2 of this document.

PART 1: DISCLOSURES ABOUT OUR BUSINESS

The first and most important rule of investing is, in our view, the most obvious:

Investing always involves the risk of loss.

As you surely have heard before, the past isn’t necessarily a guide to the future. No matter how well we do our job, no matter how much research we conduct, no matter how promising the opportunity seems, or how certain our analyst is… you cannot escape the fact that every investment opportunity (and particularly in stocks) comes with the risk of a loss. We’ve prepared this document to help you understand exactly why we publish our best investment ideas. It will explain the regulatory and legal framework that governs how we operate and will set the stage for a long and happy business relationship. We’ve been successful in this business for more than 40 years because we’ve always been dedicated to serving our subscribers by always being completely transparent about the utility of our products (track records), and by always considering how we’d want to be treated if the roles were reversed. If you’ll take the time to read this document, we believe you will be in a better position to succeed using our materials. You’ll know more about the limits of what we can help you achieve. And, most of all, you will know a lot more about the risks you inevitably face as an investor.

Most of your success as an investor will be determined by how much capital you have to invest, how much time you have to invest, and your asset allocation; that is, how much of your capital you have in stocks versus bonds and cash. If you want to be successful as an investor, our best advice is to become an expert at avoiding risk. Simply putting your money into high-quality stocks and bonds is very likely your best bet.

The first thing to know about our business is that we are NOT money managers, brokers or fiduciaries of any kind.

Our published work is NOT a low-price replacement for an experienced money manager, broker, or investment advisor. Instead, we are a publishing company and the indicators, strategies, reports, articles, and all other features of our products are provided for informational and educational purposes only. Under no circumstances should you construe anything that appears in our newsletters, reports, or on our website as personalized investment advice. Our recommendations and analyses are based on Securities and Exchange Commission (SEC) filings, current events, interviews, corporate press releases, and what we’ve learned as financial journalists. You shouldn’t make any investment decision based solely on what you read here. We urge you to get as much education as possible and to consider consulting a licensed individual advisor before making investments of any kind.

We are NOT responsible for your results — good or bad. We will NOT take credit (in the form of a percentage of your profits) for your success. Nor are we legally liable for any of your losses.

Subscribing to our newsletters will not make us responsible for your investment results. You will bear the full burden of the risks you decide to take. As we will regularly remind you: It’s your money, and it’s your responsibility. Our lack of fiduciary responsibility might cause you to second-guess our work. That’s fine with us. We urge you to be critical and skeptical of all investment recommendations, no matter the source. When you use our services (or anyone else’s) remember to always limit your position sizes to an amount you can afford to lose.

A very important warning: We make mistakes.

We are human. We make mistakes. Sometimes our ideas and hunches turn out to be wrong. Sometimes our “timing” is off. That is, an investment theme we expect to develop only does so in a time frame that makes it difficult to earn a profit. It is important for you to realize that no published materials anywhere are regularly published without at least occasional mistakes. When we make mistakes, you can count on us to correct them as quickly and honestly as possible. It is very unlikely (though it does happen from time to time) that you will become wealthy from trading stocks, bonds, options, commodities, or other financial instruments. The most realistic way to become wealthy, in our view, is by building your own business or by playing a key role in the creation or the significant growth of an existing one. Our newsletters are intended to serve people who are in the process of wealth building by helping them manage their savings, or people who already have significant amounts of savings earn a higher average return.

We don’t accept compensation from the companies we recommend as investments.

Our business either thrives or withers based on our ability to please our customers and sell subscriptions. The structure of our company and the factors that drive our profits help minimize the financial temptation to “go with the crowd” in the short term. The vast majority of our revenue is derived from renewal sales or additional sales to existing customers. We typically market to new customers at a loss. This allows us to reach more potential subscribers and, over time, to build a bigger business. It also means that unless our subscribers choose to renew in large numbers, we are unlikely to succeed at our business. This helps to align our interests with the long-term success of our subscribers. We believe we are unique in this long-term strategy among all financial publishers.

Why our business model is almost exclusively based on subscriptions.

You may have noticed that the vast majority of our products are offered only via subscription. To protect free speech and to encourage public debate and the exchange of ideas, the SEC has carved out what’s known as the “publisher’s exemption” from certain securities laws. This exemption means that we aren’t required to be registered with the SEC. To qualify for this exemption from securities licensing we must be a “bona fide” publisher that offers non-individualized investment advice to the general public on a regular basis. These policies help create accountability for publishers.

Newsletter track records

The best evaluation tool we can provide is to give you the average annual return of each recommendation made and the average holding period. This gives you the annualized return — which is an approximation of what you might have earned following the advice of a newsletter. It’s far from precise. It doesn’t account for taxes (if you’re investing in a taxable account) or “slippage” — which is the price you paid when you bought versus the recommended price and the price you got when you sold versus the recommended sell price. We can only track prices that are available in the market at the time we publish. Occasionally, someone will complain that our track records aren’t reliable because they don’t reflect actual investment returns. It’s important for you to realize that your results might be better or worse than the results we represent. We simply have no way to know what your entry price was, what your exit price was, or what taxes you’ve paid (or will eventually pay). We strive to make our track records accurate. They may, or they may not, be representative of your actual results. The most important thing that you need to understand; however, is that no single investment strategy (or investment analyst) can provide consistently market-beating advice at all times and in all markets. Our efforts are designed to allow you to use the right tools in the right market conditions.

PART 2: PROMOTION DETAILS

The following contains facts, figures, explanations, annotations, testimonial support, and other resources about the promotional piece you just viewed.

In short, these are the resources used to put together the previous promotion. As you have seen, we publish testimonials in our promotions. All of those testimonials are the words of real subscribers that we received in real letters, emails, and other feedback. If a subscriber sends a testimonial we’d like to use in a promotion, a member of our Customer Service team contacts him or her to verify his or her claims and obtains a testimonial.

When we receive testimonials from a subscriber, we veil his or her last name and any identifying details to protect his or her privacy and identity. During the verification process we’ll often ask for particulars about the subscriber’s results, including:

How much money he or she invested;
How long he or she was in the trade, and the security(ies) or other investment vehicle that was involved;
How much the subscriber made in dollar terms and as a percentage of the original investment; and
What portion of his or her overall portfolio was put into the trade.

We ask these questions because we want a clearer picture of the results that the subscriber attained so that we can pass that information on to you.

If the subscriber does not give us this information, then we do not publish his or her testimonial. We publish this information to let you know that these results are possible and have been achieved by real people after reading our research; however, you should also understand that we are advertising these testimonials because they are atypical. These results are examples of the very best possible outcomes.

Past results like these are no guarantee of any future result.

We wouldn’t recommend anticipating such outstanding results with your own investments. Yes, you could have results like these, but it’s simply not prudent to assume you will make large investment returns. Instead, we urge you to read our work carefully, to follow our risk management strategies conscientiously, and to invest cautiously while setting expectations that are based around our long-term performance averages.

You should know that the material details in this promotion are reviewed for accuracy and transparency by our in-house legal team.

The details listed below are listed in the order they appear in the accompanying promotion.

If you have any questions or want more information about the marketing material you just viewed, here’s where you should start. Remember, you can also call our Customer Service team at 800-219-8592 from Monday to Friday, 9:00AM to 5:00PM ET.