Disclosure policy

The person who owns Off Script Wire trades securities for his own account, and he is also the person who writes it. We explain that in full on our ownership page. This page is the other half: the rules we hold ourselves to because of it.

We publish it for the same reason we publish our corrections policy. A conflict you can see, with rules attached that you can hold us to, is a manageable thing. A conflict you find out about later is not.

What we disclose, on every piece

Any piece that names a specific company as a subject carries a position disclosure, at the top, under the byline. Not in the footer, not on this page instead — with the story, before you read it. It covers both the person who wrote it and Off Script Wire's owner, by name.

It runs even when nobody holds anything. That's the part that makes the rest of it worth something: if the block only appeared when there was something to admit, you could never tell an honest "no position" from a disclosure someone quietly dropped. So the block is always there, and "neither the author nor Off Script Wire's owner holds a position in this company" is a sentence we print often.

Pieces about the economy, an industry, or how something works — the large majority of what we publish — name no specific company as a subject and carry no position block. The distinction is declared by the writer on every piece and checked automatically before the site can be built; a piece that names a company as its subject and carries no disclosure does not publish.

What the disclosure says — and what it leaves out

It states, for each company the piece is about:

• Who holds it — the author, Off Script Wire's owner, both, or neither.
• Which way — long or short. Writing negatively about something you're short is the same problem with the sign flipped.
• Roughly how much, when the size is worth knowing: whether it's a small position or a material one.
• Whether we're trading it — every held position says whether it's being added to, reduced, or simply held through the quiet window. It never predicts what we'll do after that window closes, because that's a promise the market could break for us.

What it deliberately leaves out: share counts, dollar amounts, what we paid, and price targets. That isn't coyness. A disclosure that turns out to be wrong is worse than one that says less — it converts an honest omission into a false statement — so we say only what we can stand behind exactly, and we don't make forward-looking promises about our own trading that we'd then have to keep.

When we can trade

These are the timing rules. They exist to make the pattern people worry about — buy it, write it up, sell into the bounce — mechanically impossible rather than merely promised against.

Every rule below applies to a covered name: a security we have written about, or have decided to write about. That is the whole scope. We say so plainly because the alternative — letting you assume the rules cover everything we own — would be misleading by omission. Our owner trades actively, and constantly in instruments we never write about; nothing here touches that, and pretending otherwise would be a rule we'd break by Tuesday. What the scope buys you is that the rules bite exactly where the conflict lives: the name on the page.

Before any trade: the written log

A trade in a company we have named in the last 90 days, or that is on the list of things we're preparing to write about, is written down before it happens — what, when, why, and whether the name was on the coverage list at the time. The entry goes in first and the trade follows it. A note written afterwards is a recollection, not a record, and it is the timing that makes the log worth anything.

What this is and isn't. This is a contemporaneous record, not a clearance process and not an independent compliance department. One person owns this publication and writes it, so there is nobody here to approve a trade who doesn't have the same economic interest in the answer — and a signature you collect from yourself is not oversight, so we aren't going to call it that. What the log genuinely produces is a dated record of every trade set against what we were planning to publish, and that record, not anyone's approval, is the control.

Four things we never do

1. Take money to write about a security. No cash, stock, tokens, options, or anything else of value from a company, its bankers, or anyone acting for them, in exchange for coverage or a favorable mention. Ever. This is the single line whose crossing has actually gotten publishers prosecuted, and it is not a judgment call.
2. Write about a security in order to trade the reaction. Nobody here may publish about a company with the intention of moving its price and trading into the resulting strength or weakness.
3. Trade ahead of our own coverage. Once we've decided to write about something, nobody here buys it or adds to it until the piece is out — from the moment of the decision, not from when the draft starts and not from when it publishes. Knowing an article is coming is itself the advantage, and it doesn't matter how neutral the article turns out to be.
4. Give anyone personal financial advice. Every reader gets the same thing, on a schedule. We don't know your situation and we won't manage anyone's money. If you write in asking what you should do, you'll get a kind decline and a pointer to an explainer — see our disclosures.

When we get it wrong

A missing or inaccurate disclosure is a factual error in the piece and gets handled like one: a dated correction on the story itself and a note in the next issue, per our corrections policy. If a rule above gets broken, the profit attributable to the breach gets given away and documented, the affected piece is corrected or pulled, and — where it touches paid coverage or trading against our own published view — our lawyer hears about it before we publish anything else.

If you think a disclosure on one of our pieces is wrong or missing, tell us: [email protected]. Naming the piece and the line is the fastest way to get it fixed.

What's still provisional

We're pre-launch, and this policy is in front of securities counsel. The shape is settled — per-piece disclosure that names both parties, hard timing rules, a written log, and the four absolute bans. Some of the numbers may move once counsel has read it: the ten-market-day holding floor and the two-day window are our own standards rather than anything the law sets, and comparable outlets run a range around them. So is the decision to scope those rules to the companies we cover rather than to everything we own — that is a deliberate departure from how a firm with a newsroom between it and its traders would do it, it's flagged for counsel by name, and we'd rather you read it here than find it.

If they change, this page changes with them and the change is dated. What won't change is the direction: we would rather publish a rule and be held to it than publish a paragraph of reassurance and be trusted on it.

Related: Ownership · Editorial standards · Disclosures. Where this page and our Terms or Disclosures differ, the legal pages control and this one gets fixed.