Disclosures
MAR applies extraterritorially to financial instruments admitted to trading on EU regulated markets, MTFs and OTFs. A large share of US large-caps are admitted on EU MTFs without issuer involvement, so being established in Switzerland does not place this publication outside MAR. This site therefore assumes Article 20 applies and that the producer is an "expert" within Commission Delegated Regulation (EU) 2016/958 Art 1.
Producer
The natural person producing this content is named, with a job title. This is the disclosure MAR Article 2 asks for, and it is published on every page rather than on a legal notice nobody reads.
MAR obligations, article by article
Each is marked satisfied or not. An unmet obligation is stated as unmet rather than described in language that implies otherwise — that is the only version of this page worth publishing.
The identity of the producer: name and job title of all natural persons involved in producing the recommendation, and the name of the legal person responsible.
Facts must be clearly distinguished from interpretations, estimates and opinions; all substantially material sources must be indicated; projections and forecasts labelled.
- Every AI-generated passage carries a banner stating that it is model output, and states how many of its quantitative claims traced back to source data.
- Every figure the site renders from its own payload carries the licence key of the source it came from; there is no rendering path for such a figure without provenance.
- One class of number sits outside that gate and is stated here rather than left to be discovered: the model's own prose, published under a model-output banner, quotes fact-pack figures as text. Those quotations pass no provenance check and carry no licence key of their own. Every fact pack is assembled solely from sources this site may republish, so nothing quoted this way is unlicensed in substance — but the enforcement is on the payload and not on the prose, and this disclosure says so rather than implying otherwise.
- The hash of the complete fact pack given to the model for each decision is committed to the audit chain before the model is called, and is published on every decision card; direct download of the pack itself is specified and not yet available.
A summary of any basis of valuation or methodology and the underlying assumptions; an indication and summary of any change to them; the meaning of any recommendation such as buy, sell or hold; and an appropriate sensitivity analysis.
- Every mandate is published verbatim as the machine-readable YAML the rule engine actually executes — not a prose summary of it.
- The execution cost model is published verbatim, with each assumption either sourced or explicitly flagged unsourced.
- Changes to any rulebook are RULEBOOK_CHANGE events in the same hash chain as trades, with a full diff and a reason. A limit cannot be quietly loosened after a bad quarter.
- The meaning of each permitted action is published: the AI may only express direction and conviction, never a price, quantity or weight.
Disclose relationships and circumstances that may reasonably impair objectivity. Experts additionally disclose net long or short positions exceeding 0.5% of an issuer's total issued share capital, holdings by the issuer above 5%, market-making and any service agreement with the issuer.
- No client money is managed, held or received. There are no clients, no mandates and no power of disposal over anyone's assets.
- No order is routed to any venue. All trading is on paper.
- No affiliate link, issuer sponsorship, revenue share, paid placement or payment-for-order-flow arrangement exists with any person connected to any instrument named on this site.
- No market-making activity and no service agreement with any issuer named on this site.
- No net position above 0.5% of any issuer's issued share capital is held. The portfolios are hypothetical and hold no instruments in fact.
A description of the effective internal organisational and administrative arrangements and of any information barriers set up to prevent and avoid conflicts of interest.
- The AI layer ranks and explains. Its output schema has no field in which a price, a quantity, a notional or a risk limit could be expressed; the single sizing input it may offer is a requested portfolio weight, bounded by the schema, accepted only on the mandates that declare it, and clamped to that mandate's own caps by deterministic code. A test fails the build if that schema is widened.
- All sizing, pricing and risk enforcement is deterministic code the model cannot see or influence.
- The rule engine applies three gates the AI cannot bypass, and every refusal is published with a stable reason code.
- The decision, the model identity and the hash of its complete input are committed to an append-only hash chain BEFORE the model is called and before any fill price is known.
Investment firms and credit institutions must publish quarterly the proportion of recommendations that are buy, hold or sell over the previous twelve months.
The full disclaimer stack
HYPOTHETICAL PERFORMANCE — These are paper-trading portfolios. No client money is invested, no orders are routed to any venue, and no result shown here was achieved with real capital. Hypothetical results have inherent limitations and do not reflect the effect of real order flow on price.
This is not investment advice and not a personal recommendation. Nothing here is tailored to any reader's circumstances, objectives or financial situation. The published site is identical for every visitor and is never tailored. The optional research survey offered through the member channel collects aggregate market-research answers only, is never used to tailor any recommendation, and no output on this site is personalised — no code path reads a survey answer into any published content, and a test enforces that.
Portions of this site are generated by a large language model. The model can be wrong, and not every passage is reviewed by a human before publication. Passages that could not be fully traced back to source data are published with that fact stated — they are flagged, not deleted, because hiding the model's mistakes would defeat the purpose of the record.
Past performance and hypothetical performance are not indicative of future results.
Dividends are credited gross. Withholding tax is modelled at zero, which is a known simplification that FLATTERS every published return: a Swiss investor holding US equities would face 15% under the CH-US treaty with a W-8BEN, worth roughly 20 basis points a year at current index yields. The assumption is published in the cost model and stated here so it is visible without reading the configuration.
All results are shown after modelled execution costs: spread, market impact, commission, SEC Section 31 fees and FINRA TAF. The complete cost model and every assumption in it are published.
No brokerage account is connected, no order is transmitted to any venue, and no reader can trade through this site.
Published from Switzerland. Nothing here is an offer or solicitation in any jurisdiction where that would be unlawful.
Structural choices that are permanent
- Zero personalisation of anything published. The published site is identical for every visitor and is never tailored; the optional research survey collects aggregate market-research answers only, is never used to tailor any recommendation, and no output is personalised. Personalisation is the trigger that converts a publication into investment advice under Swiss and EU law and weakens the US publisher's exclusion, so tailoring is not a feature that will be added later.
- No money from anyone connected to any named instrument. No affiliate links, no issuer sponsorship, no revenue share, no paid placement, and no compensated broker placement — no broker pays to appear here, in any form, ever.
- A fixed, regular publication schedule. Never event-triggered alerts timed to market moves.
- No client money, no execution, no discretion, no mandates. Ever.
Choices that are current, not permanent
The list above is the set of commitments that will not be revisited. Anything that might be revisited belongs here instead, because a promise filed under "permanent" and then broken costs more than the promise was ever worth.
This site currently carries no "trade this at broker X" button and no brokerage integration of any kind. That is a product decision, not a permanent structural one: an uncompensated link or a public model portfolio at a broker is under consideration, and it was moved out of the permanent list rather than left there to be quietly broken. What does not change is the bullet above it — no broker, issuer or platform pays to appear on this site, and no arrangement that pays us will ever be presented as a recommendation. Any change here is recorded as a rulebook change in the same audit chain as every trade.
How permanence is enforced
- Every event is committed to a SHA-256 hash chain in which each record commits to its predecessor.
- The database blocks UPDATE and DELETE on the log table at the trigger level.
- The head hash is published daily. Save today's, and you can prove tomorrow whether history was altered.
- A portfolio can be retired but never removed, and every site-wide aggregate includes retired portfolios.
This is a map with sources, not legal advice, and nothing here substitutes for Swiss and US counsel.