Our Trading Policy
Those of you who know us realize that are all about community. We enjoy and encourage free and open dialogues on a range of technology and finance across a wide band of industries. As you might imagine, though, at times, tensions exist between what we include in our newsletters or post on our site and our work as investment advisory firm/ investment adviser to a hedge fund (the "Fund"). You should be aware of that when you read our newsletters or spend any time on our site. We have put in place a number of policies and procedures to minimize the conflicts between our editorial and written content and our advice as an investment adviser. In general, our strong bias toward is to resolve these tensions in favor of our fund investors. Highlights of our policies and procedures include:
The Fund won’t trade in a stock immediately before, and immediately after, we post a piece about it on the site. To keep from benefiting from any volatility that we might create, the Fund won’t trade a stock for a full trading day before, and a full trading day after, we write about that stock on the site. For instance, if we post a piece on a company before the market opening, the Fund will not have traded the stock during the entire prior trading session, and the Fund will not trade the stock in the entire trading session that will occur that day. If we post a piece on a company in the middle of a trading session, the Fund will not have traded that stock during the entire prior trading session, nor will the Fund trade it during the current trading session, or the next day’s entire trading session
If we change our mind about a company, we won’t necessarily post a story to say so. Please take the disclaimers we post on this site seriously. We don’t expect to post updates to articles, predictions, perspectives or opinions on a regular basis. We are a small but committed group and have to make choices about how to invest our time on a daily basis. We do not believe that providing follow-ups to past articles is the best use of a scarce resource. Even so, like all other investors, we change our minds about companies from time to time.
Sometimes we’ll post positive articles about companies we don’t own. From time to time, the Fund won’t own stock in companies we like a lot. A company’s valuation, for example, might be quite volatile in the short term. We might profile a company with a great strategy, led by a brilliant management, but with a valuation that doesn’t make sense for the Fund at the time. That doesn’t mean, though, that the company isn’t as terrific as we say it is-or might be.
Some of the companies we write about might be investors in our fund. Some of our fund investors may be institutions such as banks, bank holding companies, and non-bank financial services companies. As a matter of policy, we do not disclose the names of any of our fund investors. Thus, we may post an article about a corporate fund investor of ours-and not disclose that fact.
We hope this has been helpful. We know we have a responsibility to our readers, just as we have responsibilities to our investors. If you have any questions, feel free to shoot us an e-mail at info@coburnventures.com