Conflicts of Interest & Position Disclosures

Effective 2026-04-22 · Last updated 2026-07-20

Short version. RockTurners operates in the publisher lane under Section 202(a)(11)(D) of the Investment Advisers Act of 1940 — we publish impersonal research, we do not advise specific clients on their specific accounts. For that posture to hold, our commentary has to be disinterested. This page documents how we keep it that way.

1. Who this applies to

"We" in this document refers to Dean Systems Enterprises, LLC (which operates RockTurners as a pre-release research preview), its operators and contributors ("Covered Persons"). It also applies to contractors and advisers who have material influence over what the Service publishes.

2. Personal securities holdings

Covered Persons may hold positions in public securities that the Service analyses. We do not restrict personal investing generally — that would be unworkable for a small team — but we restrict what we publish about securities we hold.

Position disclosure on analysis pages. When the Service publishes analysis of a security in which a Covered Person holds a position of more than $10,000 (or more than 1% of issued-and-outstanding shares, whichever comes first), the project will disclose that position on the analysis page. During the current pre-release period this is handled on request to [email protected]; an in-product disclosure chip will replace this manual process before public launch.
No scalping. Covered Persons do not transact in a security within 48 hours before or after the Service publishes new research about it. This mirrors the fact pattern the Supreme Court flagged in SEC v. Capital Gains Research Bureau, 375 U.S. 180 (1963).
No coordinated publish-and-sell. We do not synchronise research publication with transaction timing across Covered Persons.

3. Paid placements, sponsored content, affiliates

No paid placements. No issuer, PR firm, or third-party pays to have a specific ticker analysed, ranked, or surfaced by the Service.
No affiliate links in research output. When the product page shows a broker, custodian, or tax-software link in the marketing footer, it is labelled as such. Research output itself contains no revenue-linked references.
If that ever changes — e.g., an explicitly labelled sponsored research section — the label will be visible on the content before the body renders, not in a footer.

4. Founder-personalized mode

The founder account uses a personalized analysis feature that includes the founder's own holdings in the prompt and emits BUY/HOLD/SELL ratings. That feature is server-gated to the founder_flag = true user row and is not reachable by other users via any request payload. The founder is the publisher, not a client, and the personalized output is not re-published outside that account.

5. Human-in-the-loop on model output

Every AI-generated artifact is framed, rendered, and (on the research-lane branch) post-scrubbed against advice-verb patterns before publication. See our AI Disclosure for the architectural details. The purpose of that posture is to keep the publication disinterested and impersonal — the controls exist regardless of what the underlying model happens to produce.

6. Corrections & right of reply

If you are an issuer, investor relations contact, or third party who believes the Service's research about you or your securities contains a material factual error, email [email protected]. We log every request, respond within 5 business days with a determination, and publish corrections on the same analysis page that carried the original content. We do not remove negative analysis in response to request alone; removal requires a material factual error, a security being delisted, or a legal demand we reasonably conclude is correct.

7. What we do not do

We do not hold or have discretion over user funds.
We do not route orders to any brokerage.
We do not provide personalized investment advice to any user other than the founder-flagged operator account described in section 4.
We do not accept performance-based compensation from any user or third party.

8. Contact

Conflict-of-interest questions, factual corrections, and everything else: [email protected]

This page describes operating policy, not a safe harbor. Nothing here creates a duty running to any third party beyond what is imposed by applicable law.