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Managing Conflicts of Interest
ARRANGEMENTS FOR MANAGING CONFLICTS OF INTEREST

1. Overview

The key focus of managing conflicts is to ensure our research, strategies and/or recommendations have credibility and integrity and can reasonably be relied upon by our clients.

Although authorised pursuant to its AFS Licence to do so, RCC does not provide personal advice. Notwithstanding, RCC will take into consideration our clients’ best interest. In addition, RCC does not receive conflicted remuneration and does not provide its representatives conflicted remuneration.

2. Structural Arrangements to Manage Conflicts of Interest

RCC uses the following mechanisms to manage conflicts of interest:
• controlling the conflicts of interest;
• disclosing the conflicts of interest; and/or
• avoiding the conflict of interest.
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3. Procedures for Controlling Conflicts of Interest

To control conflicts of interest RCC has:
• identified the conflicts of interest relating to its business;
• assessed and evaluated those conflicts; and
• decided upon, and implemented, an appropriate response to those conflicts.

(a) Remuneration practices

RCC has minimal conflicts of interest with regard to providing its services and it is controlled by clearly disclosing the remuneration structure in the FSG.
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All RCC representatives (who are employees) are remunerated by way of salary and discretionary bonus based upon performance. Authorised Representatives are paid a fee per chart analysis they provide. Accordingly, the control implemented to manage this minimal conflict of interest is to ensure all recommendations are based on thorough and complete research.

(b) Treating clients fairly

RCC provides generic recommendations based on technical analysis undertaken. Accordingly, all clients receive the same advice based on RCC's view and thus, all clients are treated the same. 

4. Procedures for Disclosing Conflicts of Interest

Representatives of RCC (or any associated person) may, at times have a legal or beneficial interest in the financial products that are the subject of the financial product advice if they have invested in that product.

The Directors of RCC (and its other representatives) will disclose if they hold a position that is being recommended on the appropriate webpage of the secure area of the website. This information will be easily found and prominent to clients.

All research reports are issued (distributed) after the ASX market close allowing clients to implement any recommendations they choose to follow on the opening of the ASX market. The Directors of RCC (and its other representatives) may also choose to implement the RCC recommendation and will do so on the opening of the ASX market. 
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OCTOBER 2018

All content available on this website, www.tradelongterm.com (this “Website”), is general in nature, not directed or tailored to any particular person, and is for informational purposes only.  Neither the Website nor any of its content is offered as investment advice and should not be deemed as investment advice or an offer, solicitation, or recommendation to purchase or sell any specific security.  The information contained on the Website reflects the opinions and projections of the authors of the Website (the “Authors”), which are subject to change without notice at any time.  The Authors do not represent that any opinion or projection will be realized.  Neither the Authors nor any of their affiliates represent that the information presented on this Website is accurate, current, or complete, and such information is subject to change without notice.  Past performance is not a guarantee of future results.  Authors may own the stocks they highlight or discuss and, in fact, do own the stocks contained in the Premium Portfolio.

IMPORTANT INFORMATION

Commodity Futures Trading Commission (CFTC) Rule 4.41

HYPOTHETICAL PERFORMANCE RESULTS HAVE MANY INHERENT LIMITATIONS, SOME OF WHICH ARE DESCRIBED BELOW. NO REPRESENTATION IS BEING MADE THAT ANY ACCOUNT WILL OR IS LIKELY TO ACHIEVE PROFITS OR LOSSES SIMILAR TO THOSE SHOWN. IN FACT, THERE ARE FREQUENTLY SHARP DIFFERENCES BETWEEN HYPOTHETICAL PERFORMANCE RESULTS AND THE ACTUAL RESULTS SUBSEQUENTLY ACHIEVED BY ANY PARTICULAR TRADING PROGRAM. ONE OF THE LIMITATIONS OF HYPOTHETICAL PERFORMANCE RESULTS IS THAT THEY ARE GENERALLY PREPARED WITH THE BENEFIT OF HINDSIGHT. IN ADDITION, HYPOTHETICAL TRADING DOES NOT INVOLVE FINANCIAL RISK, AND NO HYPOTHETICAL TRADING RECORD CAN COMPLETELY ACCOUNT FOR THE IMPACT OF FINANCIAL RISK IN ACTUAL TRADING. FOR EXAMPLE, THE ABILITY TO WITHSTAND LOSSES OR ADHERE TO A PARTICULAR TRADING PROGRAM IN SPITE OF TRADING LOSSES ARE MATERIAL POINTS WHICH CAN ALSO ADVERSELY AFFECT ACTUAL TRADING RESULTS. THERE ARE NUMEROUS OTHER FACTORS RELATED TO THE MARKETS IN GENERAL OR TO THE IMPLEMENTATION OF ANY SPECIFIC TRADING PROGRAM WHICH CANNOT BE FULLY ACCOUNTED FOR IN THE PREPARATION OF HYPOTHETICAL PERFORMANCE RESULTS AND ALL OF WHICH CAN ADVERSELY AFFECT ACTUAL TRADING RESULTS.

This brief statement cannot disclose all of the risks and other significant aspects of securities and derivatives markets.

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