A Journal of Independent Research, Analysis,
 Opinion and Insight

  Research Disclosures

Welling on Wall St. LLC believes that its reputation for journalistic enterprise, intellectual independence and absolute integrity are essential to its mission. Our readers must be able to assume that we have no hidden agendas; that our facts are thoroughly researched and fairly presented and that when published our analyses and opinions reflect our best  judgments  - and not the vested pocketbook interests of our sources, our colleagues, our clients or ourselves.

WellingonWallSt.'s mission is to provide our readers with thoroughly independent research, trenchant analysis and opinions that are as considered as they are provocative. We work tirelessly to fulfill that mission. That said, you must also consider that no one, and no organization is perfect, and be assured that our lawyers advise that we tell you so. So here it is, in plain language, not the usual lawyer-ese.

All the material in this publication is based on data from sources that we have every reason to believe are accurate and reliable. But we can't (nor can anyone else) guarantee it to be utterly accurate. And there's always a chance, though we strive to avoid it, that we've missed something. So we make no claim that it is complete; the end-all and be-all.  Opinions and projections found in this report reflect either our opinion or that of our interviewees or guest authors (all of whom are clearly identified) as of the original interview/publication date and are subject to change without notice. When an unaffiliated interviewee's opinions and projections are reported, WellingonWallSt. is relying on the accuracy and completeness of that individual/firm's own research disclosures and assumes no liability for those disclosures, beyond reprinting them in an adjacent box.

This report is the product of journalistic enterprise and research. It is NOT a sales tool. It is not intended to be - and should NOT be mistaken for - an offer to sell anything. It is NOT a solicitation for any sort of Investment or speculation. It should NOT form the basis for any decision to enter into any contract or to purchase any security or financial product. It is entirely beyond the scope and, bluntly, competence of this publication to determine if any particular security is suitable for any specific subscriber. In other words, we don't give investment advice. Don't mistake anything you read in WellingonWallSt. for investment advice. This publication does not provide sufficient information upon which to base an investment decision. WellingonWallSt. does advise all readers to consult their brokers or other financial advisors or professionals as appropriate to verify pricing and other information. WellingonWallSt., its affiliates, officers, shareholders and associates do not assume any liability for losses that may result if anyone, despite our warnings, relies on any information, analysis, or opinions in the publication. And, of course, past performance of securities or any financial instruments is not indicative of future performance. All information gathered by WellingonWallSt. staff or affiliates in connection with her/his job is strictly the property of WellingonWallSt.  It is never to be disclosed prior to publication to anyone outside of WellingonWallSt. and is never to be used, prior to publication-and for two week thereafter-as the basis for any personal investment decision by staff, affiliates and/or members of their immediate households. All staff and affiliates  of WellingonWallSt. will avoid not only speculation but the appearance of speculation and may not engage in short-term trading, the short selling of securities, or the purchase or sale of options, futures, or other derivatives, including ETFs reliant on derivatives. Any equity or fixed-income investments entered into by WellingonWallSt. staff or affiliates will be held for a minimum of six months unless dispensation is received, under extraordinary circumstances, from Welling on Wall St. LLC's legal counsel.  Any pre-existing direct investment interest in any stock, mutual fund, ETF or partnership portfolio covered in an issue of WellingonWallSt. will be specifically disclosed in that edition and that position will be frozen for at least a month.