Guidelines for Ethical Collaboration
These Guidelines for Ethical Collaboration (Guidelines) are written to facilitate ethical collaboration between members of the StoryTrading community. These Guidelines apply to all users of the StoryTrading platform, including employees, contributors, presenters, and third-parties. Please see the disclaimer at the bottom of the Guidelines.
Insider trading is the trading of a company’s stock or other securities by individuals with access to confidential or non-public information about the company. Federal securities laws define “insiders” as a company’s officers, directors, or someone in control of at least 10% of a company’s equity securities. Where an insider “tips” a non-insider about non-public information that may influence a company’s publicly-traded stock price, the non-insider may also be imputed with the same duty as the insider.
If you are an officer, a director, or someone in control of at least 10% of a company’s equity securities, you should refrain from disseminating non-public information to the StoryTrading community.
If you obtained non-public information by any other means, you should refrain from disseminating it to the StoryTrading community.
If you learn of non-public information about a public company, do not trade on it or share it with the StoryTrading community.
Information about a company that is gathered from publicly available sources is not non-public information, and you are free to trade on it.
You may trade on information received from an officer, director, or someone in control of at least 10% of a company’s equity securities if you neither know nor have no reason to know that the information you are receiving is confidential or non-public information.
Frontrunning is the practice of trading a security with the foreknowledge that a large, non-publicised transaction will take place and influence the share price of the security. “Index front running” is the buying of stocks before they are added to indexes that passively managed funds are designed to track.
If you are a broker, make sure you are aware of frontrunning regulations if you intend to purchase stocks both for your personal portfolio and for your clients.
If you are scheduled to present a VIP pick to the StoryTrading community, it is permissible to inform others of your intention to do so.
Frontrunning is not illegal if it is based on publicly available information.
Index front running is a permissible trading activity.
Low Float and Pump-and-Dump
A float is the number of outstanding shares available to trade in a stock, excluding the restricted shares — i.e., it is the number of shares that are free to trade in the open market. A pump-and-dump is a fraudulent scheme involving use of false or misleading statements to increase a stock’s share price, and then selling the stock for a profit.
When promoting or presenting stocks with a market capitalization of less than $100 million to the StoryTrading community, your promotion or presentation must be based on a strong fundamental thesis.
When investing in low float stocks you became aware of via the StoryTrading platform:
- Check the age of the company
- Research who is in charge of the company
- Pay attention to the trading volume of the stock
- Dedicate time and attention to low float stocks in which you own shares
As a member of the StoryTrading community, you are not committing any crime by simply trading the momentum of a stock, provided you are not knowingly attempting to manipulate the value of a stock for profit.
Trading a stock because you have reason to believe other members of the StoryTrading community are doing the same is not illegal.
Disclosing Relationships / Conflicts of Interest
A conflict of interest could arise in any circumstance in which the interests of an individual StoryTrading VIP presenter or user are at odds with those of the StoryTrading community.
Disclose who you are, who you work for, and any other relevant affiliations with the StoryTrading community, including whether you are communicating on behalf of yourself or another company.
Disclose if you receive compensation, directly or indirectly, in connection with any stock your present or promote.
When promoting or presenting a stock, disclose all material facts relating to the scope or terms of your relationship with the stock you are presenting, if any.
If you are presenting a VIP pick, you are not required to disclose your position in that stock.
If you previously presented a VIP pick to the StoryTrading community, you are not required to update StoryTrading if your position changes after presenting your VIP pick.
The information in these Guidelines is intended to provide general legal information. It does not constitute legal advice and should not be construed as such. If legal, tax, financial, accounting, investment advisory, or other professional advice is required, consult a licensed attorney in your area to get advice that is specific to you. It is your responsibility to ensure that you are familiar with all potentially applicable regulations including, for example, the SEC’s Regulation AC and its application to research analysts. These Guidelines are written in consideration of potentially applicable regulations, including those promulgated by the Federal Trade Commission (FTC), Consumer Financial Protection Bureau (CFPB), the Securities and Exchange Commission (SEC), and other federal and state regulators.