Stansberry Asset Management, LLC
Solicitor Disclosure
Stansberry & Associates Investment Research, LLC (“Solicitor”) is a subscription-based publisher of financial information. Solicitor and Stansberry Asset Management, LLC (“Adviser”) are separately operated and overseen by different boards.
Although Adviser will utilize investment research published by Solicitor, Adviser has no special or early access to such research. Adviser receives information from Solicitor just like any other subscriber does – after the issues are published.
This disclosure is being provided to you by Solicitor in accordance with Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended.
Solicitor is not a current client or investor of Adviser. Adviser provides cash compensation to Solicitor for Solicitor’s advisory client solicitation services for the benefit of Adviser. Material conflicts of interest may exist due to Solicitor’s economic interest in soliciting clients for Adviser. Certain Solicitor personnel may also have limited rights and interests relating to one or more parent entities of Adviser.
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Name of Solicitor: |
Stansberry & Associates Investment Research, LLC |
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Name of Investment Adviser: |
Stansberry Asset Management, LLC |
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Is Solicitor a Current Client of Adviser or an Investor in One of its Funds? |
No |
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Is Solicitor Compensated by the Adviser for its Solicitation Activities? |
Yes, Solicitor and Adviser have entered into a written agreement whereby Solicitor is to be compensated in cash for the Adviser’s use of the “Stansberry” name, for advertisements on behalf of the Adviser in Stansberry Research publications and for the Solicitor’s advisory client solicitation services for the benefit of the Adviser (the “Agreement”). |
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The Material Terms of the Compensation Arrangement between the Solicitor and the Adviser include: |
The Adviser shall compensate the Solicitor with a flat fee of $4500.00 for each solicited client that enters into an investment advisory agreement with the Adviser. The Agreement may be amended in the future by mutual agreement of the Adviser and the Solicitor. |
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The Material Conflicts Resulting from the Relationship Between the Solicitor and Adviser Include: |
Solicitor has an economic interest in recommending Adviser to solicited clients. This economic interest can inform Solicitor’s recommendation of Adviser in addition to a solicited client’s interests. Additionally, certain Solicitor personnel may have certain limited rights with respect to the governing body of one or more parent entities of the Adviser. Certain Solicitor personnel may also have economic interests (including non-controlling ownership or profits interests but excluding any form of compensation) with respect to one or more parent entities of the Adviser. Such rights and interests can also inform Solicitor’s recommendation of Adviser in addition to a solicited client’s interests. |
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Other Information: |
Solicitor’s officers, editors, writers and other employees are prohibited from controlling the Adviser by any means, including through ownership, contract or otherwise. Similarly, members of the Adviser’s management team and officers and employees of the Adviser are prohibited from controlling the Solicitor by any means including through ownership, contract or otherwise. Solicitor and Adviser are and will remain separate corporate entities that are separately operated and are overseen by different boards and different management teams. Adviser’s management team is responsible for the investment decisions of Adviser. No member of Adviser’s management team nor any other officer or employee of Adviser is an officer, editor or writer or other employee at Solicitor. Similarly, no officer, editor, writer or other employee at Solicitor is an officer or employee at Adviser. |