Disclosure

Disclosure

I’ve made the first purchase for my portfolio! It happened much sooner than I expected, as I have been thinking that there are relatively few opportunities out there.

However, things change, I made a snap purchase (I have been watching the company for a while), and this unfortunately brings me to another dilemma that I had not considered yet – disclosure.

While I will to write about all actions that I take with this portfolio, I had not yet considered disclosure and there is a significant grey area around buying or selling shares and writing about them. This blog is for my own personal use and nothing here is a recommendation. However, I do anticipate that at some point I will attract some readers, and I must act with propriety.

I have looked at popular Australian share advisory websites like Intelligent Investor and they do not permit staff trading one business day before or after an article, although all trades require compliance permission. The Motley Fool does not permit trading for two business days before or after an article, and staff also require compliance permission. I note however that these businesses actually have compliance departments and an Australian Financial Services License, while I do not.

For the time being I have decided that I will wait 1 week (7 calendar days, not business days) before commenting on a trade. I do not envision there being any issues on this point but i also I will hold all shares that I purchase for 1 month. I have updated my disclaimer and ‘The Rules’ to reflect this fact. I may at times (within the 7 day period) write a brief piece, like today, noting that I have made a purchase, however I will  aim to omit specific details that could  allow the company to be identified indirectly within that period.

I do not plan to short-sell any securities at this point but if I do, I may have to amend the rules on my disclosure page. I will likely have to come up with a different scheme, since I perceive that flexibility is very important attribute in taking short positions, but that is not necessary for now.

You’ll be able to read about my first purchase in a few more days.

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