Disclaimer

Investing always involves the risk of loss.

Paradoxically, investing is often most risky when it appears safest. This lesson of history led us to adopt a rather unconventional strategy – a contrarian approach to investing. We believe our approach has great merit, based upon our reading of history of our own track record to date. But 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, or certain our analyst… you cannot escape the fact that every investment opportunity (and particularly in cryptos) comes with the risk of a loss. These risks are part of the reason why great investment ideas are rare and incredibly valuable. You should understand why a business – like ours – would be willing to share investment ideas with you and under what terms. We’ve prepared this document to help you understand exactly why we publish our best investment ideas (instead of simply investing in them or managing a hedge fund or other investment pool). It will give you insight into the specific conflict of interest we face as publishers and describe how we collect our track records. It will describe our posture in regards to guarantees and refunds. It will explain the regulatory and legal framework that governs how we operate and perhaps most important, it will set the stage for a long and happy business relationship. We’ve been successful in this business over many years because we’ve always been dedicated to serving our subscribers by only publishing materials we’d want our own families to read and follow, 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 far more likely to succeed using our materials. You will know more about our approach to serving investors. 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.

The first thing to know about our business (Keystone Investors) 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, Keystone Investors is 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 analysis are based on Securities and Exchange Commission (SEC) filings, current events, interviews, corporate press releases, and what we’ve learned as financial journalists. It may contain errors, and you shouldn’t make any investment decision based solely on what you read here. If you are not an experienced investor, we urge you to get as much education as possible and to consult a licensed individual advisor before making investments of any kind. The regulatory regime for investment advisors and money managers makes it difficult (if not impossible) to serve both the general public and individuals. We have chosen to provide our research to the general public for a number of good reasons. For one, we know that Wall Street has enjoyed a dramatic advantage over the average investor for decades. And we want to level the playing field as much as possible. But the most important reason for serving the general public relates to something called the “prudent man” rule. Historically, the best investment opportunities have arisen amid circumstances most investors believed were risky. For example, opportunities to buy large-cap U.S. stocks at attractive prices have occurred almost exclusively during periods of great economic uncertainty. Recently such opportunities arose in 1987, 1994, 1998, 2002, and 2008. We are confident that such opportunities will occur again. Excessive greed and fear are the emotions that drive the public markets. Likewise, individual securities often trade at the most attractive prices when serious problems arise in a given business. We call these company-specific problems “warts.” However, precisely because most investors are repulsed by such securities, investors willing to study them can produce large investment returns. We seek to take advantage of these opportunities for the benefit of our subscribers. As I’ll explain later, our firm does not own any stocks, nor do we allow our investment analysts to own the stocks they recommend for our subscribers. Investment fiduciaries are often forbidden by regulations – most notably the so-called “prudent man” rule – from taking a contrarian approach like ours with a majority of their investments.

Our company’s primary approach to investing is based in contrarian strategies that may be significantly at odds with conventional wisdom and mainstream approaches to capital management.

That means many of the recommendations and strategies we cover in our publications will seem risky and controversial. It also helps explain why investors and media outlets that follow a more conventional “prudent man” approach frequently criticize our work and even accuse us of malfeasance. We urge you to consider our investment ideas carefully and to follow all of our strategies for risk management, especially position sizing and trailing stop losses. But most of all… we urge you to educate yourself about the philosophy that underlies our approach. If you will take the time to understand why we believe our strategies are likely to work, you can acquire the emotional fortitude and the discipline necessary to successfully apply our strategies. If you lack this understanding, you are very unlikely to succeed.

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. But the simple fact is, if we were subject to legal liability for any losses resulting from our recommendations, our business would disappear overnight. No investment manager could withstand the risk of investment losses without also reaping the rewards of investment gains. Being free of these fiduciary obligations allows us the freedom to operate and to provide information about investment strategies (contrarian) and investment ideas that others are not able or willing to cover. Therefore, when you use our services remember to always limit your position sizes to an amount you can easily afford to lose. (We’d recommend the same advice when making an investment based on a recommendation from any source.)

A very important warning: We make mistakes.

We are human. We make mistakes. Sometimes our ideas and hunches turn out to be wrong (though not often, we’re pleased to report). More frequently our “timing” is off. That is, an investment theme we expect to develop only does so in a timeframe that makes it difficult to earn a profit. And of course, there are also times when we are misled, despite reasonable efforts to confirm our sources. Based on the large number of customers we have acquired and retained and based on our own internally kept track records (more on these below), we feel confident that on the whole our work is extremely reliable. We doubt you’ll find work by any other publisher that is as detailed and well-sourced. Nevertheless, it is important for you to realize that no published materials anywhere – not even the New York Times – is 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 cryptos, 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.

Why not simply manage money or keep our ideas for ourselves?

Most knowledgeable investors are willing to share their ideas with other investors in exchange for a fee. Sharing ideas doesn’t reduce returns and can generate substantial amounts of income for good investors. Fees for top-quality money managers are high – especially for investors who are able to pursue contrarian strategies. Hedge funds, for example, typically charge 2% of assets under management and 20% of profits. Fees generated by successful hedge funds can reach into billions of dollars. While we have considered for many years launching such a fund, the regulatory burden and the cost of raising large amounts of capital, are significant. On the other hand, thanks to the First Amendment, there are relatively few legal burdens to publishing and thanks to the Internet, there are few capital constraints. These low barriers to entry allowed us to achieve a significant amount of success very quickly. We know of no other business in our industry that has ever achieved growth equal to even a fraction of these numbers so quickly. We don’t believe such rapid success would have been possible if we’d attempted to build a money-management business. You should know that we attribute our success to three simple factors: our contrarian approach (we cover valuable opportunities others won’t or can’t), the number of very highly skilled analysts we were able to recruit and retain (primarily by offering a work environment that promised lucrative rewards for success with almost no conflicts of interest), and the integrity with which we have always approached our endeavors. We decided to publish our investment ideas to millions of people around the world at a relatively low price rather than sharing our ideas exclusively with a very small group of wealthy investors at a high price. In the long term, for this approach to be successful, we must continue to provide large numbers of subscribers with unique, contrarian investment advice that is reliable and profitable.

We have structured our business in an effort to avoid conflicts of interest, but a significant potential conflict of interest still exists.

We believe everyone involved in finance has some conflict of interest. Hedge-fund managers, for example have a tremendous incentive to produce short-term capital gains so that they can generate fee income (20% of gains). This might lead them to take short-term risks at the expense of safer and more lucrative long-term gains. This conflict will exist even if the manager keeps all or most of his wealth inside the fund. It also helps explain why successful hedge-fund managers often end up earning far more from running the fund than their clients make investing in it. We generate our profits exclusively from the subscriptions we sell. This is deliberate. We do not want our subscribers to wonder whether we were recommending a company or an investment because the company or investment sponsor advertised with us. This has been one of the ways that we have steered clear of potential conflicts of interest but it’s not the only one.

We don’t accept compensation (or favors) from the companies we recommend as investments. 

As you may know, many newsletter companies do not adhere to the same guidelines that we do. Some accept compensation from the companies whose crytpo they recommend and cover. We could argue that our policies described above leave us completely free of any conflict of interest. Other financial publishers will surely make such a claim. But it’s not completely true. We have made efforts to structure our business so that we don’t have any conflicts of interest. But despite our efforts, we do have a conflict. It’s a conflict that’s systemic throughout the investment community and complex to explain… so bear with me. The investing public has the unfailing tendency to rush into the worst possible investments at the worst possible time. We call this the “paradox” of finance. People can figure out when it’s a good time to buy groceries – when they’re on sale. But when it comes to securities, people tend to ignore them when they’re cheap and stampede into them when they’re expensive. For example… you’ll remember that in 1999 and 2000 investors all rushed into tech stocks… at the wrong time. Then, they rushed into the housing market… at the wrong time. We believe this irrational behavior is linked to the emotional need many people have to conform. It’s the same psychology, essentially, that powers the fashion business. We can’t say what investment passion will strike the crowd next, but we know, when it occurs, it would prove lucrative for us to publish information confirming the crowd’s passions… even when it involves making bad or dangerous recommendations. That is, during bubble periods, we have a financial incentive to help inflate the bubble because that’s the kind of information the public will demand in those periods. This conflict – the temptation to sell the public the information it wants even if it’s not in their interests – isn’t unique to financial publishers. All forms of media face this conflict. That’s why, at market tops, you will commonly find magazine covers and other types of mainstream media embracing the bubble. We attempt to balance this conflict by focusing on proven contrarian approaches to investing. We further advocate strict risk-management strategies that have so far largely prevented us from being caught up in investment manias. You should also know that 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. Essentially all of our profits are 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. Just to be clear, though, no financial business is totally immune to all conflicts of interest – just as no investment is totally free of risk. No matter how dedicated our executives are to the success and wellbeing of our subscribers, at least some of our employees will be motivated by a need to sell, to motivate, to persuade, and to captivate our subscribers to produce revenue for our business. It is difficult to sell anything without embracing, at least somewhat, the mood of the public. Thus, we urge all subscribers to reference our most recent newsletters and to consult with an individual advisor before making any investments. Likewise, we would urge you not to rely – at all – on any of our marketing pieces or sales letters when making your investment decisions. These publications are designed to sell our research products and thus, by design, lack the more fully balanced analysis of the risks and rewards of any particular investment idea that you will find in our newsletters.

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 doesn’t mean that we can write whatever we want. It means that we aren’t required to be registered with the SEC. And it means that we can write about things registered advisors would find difficult to get through their compliance departments – such as extremely contrarian advice. To qualify for this exemption from securities licensing (and avoid the “prudent man” restrictions we mentioned earlier), we must be a “bona fide” publisher, which under law is defined as a publisher who offers commentary to the public on a regular schedule via subscription. The SEC frowns on “tip sheets” that sell one-off reports. These policies help create accountability for publishers. If we aren’t able to live up to our promises and the expectations we set, our clients have the right to demand a refund. We have no problem proving our value to subscribers. It’s exactly how we’d want to be treated if our roles were reversed.

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