Disclosures:
Our Process and D.I. Ratings™ Explained:
Each D.I. Report® and the D.I. Rating™ included therein is the product of our gathering and analyzing data on about 100 separate risk factors on a public company over the most recent five-year period available. We are simply looking at the risk factors that can destabilize a public company and/or distract its management so much as to interfere with any underlying fundamentals. D.I. Ratings™ and D.I. Reports® are generated using a patent-pending risk-rating methodology we designed to help investors better assess the risk of public companies.
The following are the D.I. Ratings™ we may assign:
High Risk: These are companies that carry so much risk as to have the capacity to potentially overwhelm any underlying fundamentals. The reward for owning the stock carrying the High Risk rating needs to be sufficient to overcome this level of risk.
Medium Risk - Positive Bias / Medium Risk - Negative Bias: Investors either long or considering going long stocks with this rating need to carefully monitor these holdings against the risk factors we highlight. These are companies where we found at least one risk factor that concerns us. The bias we assign (positive or negative) reflects our opinion of whether the risk profile for the company is improving or degrading. The risk(s) we found add a level of uncertainty or potential for surprise if ignored.
Low Risk - Buy Candidate: These are companies we found that carry a low risk profile.
Intellectual PropertyThis material is copyrighted 2000 to 2009 by Disclosure Insight, Inc. All rights reserved. The works of authorship contained in the accompanying material, including but not limited to all data, design, text, images, charts and other data compilations or collective works are owned by Disclosure Insight, Inc. or one of its affiliates and may not be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, or stored for subsequent use, in whole or in part in any manner, without the prior written consent of Disclosure Insight, Inc.
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Disclosure Insight®, D.I.™, D.I. Score®, D.I. Rating™, D.I. Profile®, D.I. Database®, D.I. Report®, D.I. Watch List®, D.I. Focus List®, D.I. Mailbox™, Better Disclosure for Better Decisions®, 5 Years of Due Diligence in One Report™, Assess the Risk. Achieve the Return.™, D.I. Favorites™, and Just Because its Public Information Doesn’t Mean it’s Public Knowledge® are service/trademarks of Disclosure Insight, Inc. and are proprietary. Information Provider/PublisherDisclosure Insight, Inc. is an independent investment research provider that primarily publishes and provides its research for institutional investors. We use proprietary methods to gather data and records on public companies, analyze them, and publish our findings. We frequently employ open records law, such as the Freedom of Information Act and other legal means to acquire data and records. We strive to conduct a thorough review and analysis of the records we receive. The information and reports we publish, including the D.I. Score™ risk ratings we assign, reflects our sincere opinions about companies, industries, and/or themes about which we believe our readers may be interested.
Where we express opinions about or assign D.I. Score™ risk ratings to public companies, they are strictly in relation to, and based on other data, information, and/or documents Disclosure Insight, Inc. has in its database or has acquired. Disclosure Insight, Inc. makes no representations regarding the materiality, completeness or accuracy of any information or documents we provide. Questions regarding the same should be directed to the referenced company or companies.
While Disclosure Insight, Inc. may assign risk ratings and/or express opinions regarding the risk profile of companies, it is not in any way acting in the capacity of a financial advisor or broker/dealer. The information provided by us should not be construed by any subscriber or prospective subscriber as Disclosure Insight, Inc.'s solicitation to effect, or attempt to effect, any transaction in a security. The information that we provide or that is derived from our website should not be a substitute for your own due diligence which may include advice from an investment professional.
Disclosure Insight, Inc. is not registered as an investment adviser. We rely upon the "publishers' exclusion" from the definition of investment adviser under Section 202(a)(11) of the Investment Advisers Act of 1940, as amended, and corresponding state securities laws. As such, Disclosure Insight, Inc. does not offer or provide personalized advice.
Disclosure Insight, Inc. routinely receives “tips” and similar input from subscribers and others regarding companies, industries, and/or themes we may or may not conduct research on. Subscribers may also submit a list of those securities that they like to be kept informed about. We may or may not act upon these tips, requests, and/or watch lists. We make no representations regarding the criteria we employ in deciding the same. Subscriber interest or tips have no influence whatsoever on the content of the printed research itself. Regardless of a tip, request, or presence of a name on a subscriber’s watch list, all reports are posted to our website. As such, they are also equally disseminated and available to all subscribers at the same time.
From time-to-time individual subscribers or prospective subscribers may speak to us regarding our research reports or the process employed in creating these reports. To the extent we engage in these discussions they are typically in relation to, and based upon, the processes employed by Disclosure Insight, Inc. in developing these reports, or on other data, information, and/or documents Disclosure Insight, Inc. has in its database or has acquired. Such conversations may be focused on how open records and similar laws work, aspects of our risk rating methodology, or background on practice and procedure of the Securities and Exchange Commission. Because of the wide range these discussions can encompass, it is possible we may release information in these discussions that is not already or completely reflected in our published work. At no time in these conversations will we provide personalized or individualized investment advice nor will we offer advice regarding a subscriber’s individual circumstances. In addition, at no time in these conversations will we solicit to effect, or attempt to effect, any transaction in a security.
From time-to-time individual subscribers or prospective subscribers may ask us to engage our information/records acquisition capabilities to acquire specific records through various lawful means such as the Freedom of Information Act or certain aspects of the patent-pending risk rating methodology we use to assemble our reports. This can include provision of D.I.® Analyst Notes. At our discretion, we may choose to engage in this information-gathering activity, typically for a negotiated fee. Depending on the interest that we perceive such information may have to the broader subscriber base, we may or may not make these records available to all subscribers. Typically, this work product will be not be widely disseminated. We make no representations regarding the criteria we employ in deciding whether to release such records and/or information. We assume no obligation to disclose if and/or when we engage in such activities.
Privately-Held Company
Disclosure Insight, Inc. is a privately-held publisher that is not in any way affiliated with the U.S. Securities and Exchange Commission (“SEC”) or any other branch or agency of government. Disclosure Insight, Inc. is affiliated with FOIA Insight, Inc., both of which are private companies that currently are under common ownership. Any of them may file open records requests from time-to-time. Disclosure Insight, Inc. and FOIA Insight, Inc. presently rely entirely on the resources of Disclosure Insight, Inc. and its principals, employees, affiliates or agents to conduct their business.
Potential Conflicts of InterestDisclosure Insight, Inc. requires its employees and principals to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct regarding potential conflicts of interest. This includes prohibiting its employees and principals from trading in their own accounts in any manner which might be deemed in conflict with client subscribers.
Further, and with few exceptions, Disclosure Insight, Inc. prohibits its employees and principals from trading of any kind in any individual public company securities, or derivatives thereof, on any company on which production of a new D.I. Report® has commenced. Such prohibitions shall remain in place until either 5 days after the individual D.I. Report® has been published or its production otherwise ceases. In addition, Disclosure Insight, Inc. prohibits its employees and principals from trading of any kind in any individual public company securities, or derivatives thereof, on any company on which we have received a response from the United States Securities and Exchange Commission (or other regulatory authority) to one of our Freedom of Information Act (FOIA) requests which suggests the presence of an undisclosed SEC or other governmental investigation and/or law enforcement activity. Such prohibitions on newly received FOIA data shall remain in place from when the material is received until either 5 days after it has been published or production on the data point otherwise ceases.
On a severely limited basis, we will permit employees to engage in trading of the sort that would be deemed in conflict with this policy such as “extreme financial hardship” as defined by the CFA Institute Code of Ethics.
Disclosure Insight, Inc. otherwise permits, and encourages, its employees to freely trade in any securities so long as such trading is not deemed as in conflict with this policy or client subscribers. We similarly place no holding period limits or restrictions on such personal trading. This could, and often does, include trading in mutual funds, exchange traded funds (ETF’s), and derivatives thereof which may include covered names as components of the overall funds and/or ETF’s.
Disclosure Insight, Inc. does not engage in investment banking activities or take any security positions, except those necessary for routine corporate treasury functions.
The CEO/President of Disclosure Insight, Inc. owns First Watch Investment Advisors, LLC, (“First Watch”) a registered investment adviser. First Watch is a fee-only investment adviser that primarily provides investment advice to clients regarding matters of asset allocation, investment policy, investment selection, and financial planning.
As an entity, First Watch is not a broker-dealer, does not engage in investment banking activities, and takes no security positions except those necessary for routine corporate treasury functions. First Watch may oversee certain retirement and other accounts for employees of Disclosure Insight, Inc.
First Watch may use research generated by Disclosure Insight, along with other data, in making decisions for its managed accounts. In order to adhere to its obligations to clients First Watch may have executed transactions for its managed accounts in securities prior to their being mentioned in any of our publications. Further, First Watch may make investment decisions, render advice, trade, or hold securities for its managed accounts that are inconsistent with, or contrary to, the views expressed in current Disclosure Insight, Inc. reports or coverage. For more information on First Watch, go to www.fwinvest.com.
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