The Distressed Debt Investors Club Compliance Policy and Procedures

ALL USERS OF THE DISTRESSED INVESTORS CLUB MUST ADHERE TO THE DISTRESSED INVESTORS CLUB'S COMPLIANCE PROCEDURES (THE "POLICY"), THIS POLICY HAS BEEN INCORPORATED INTO THE DISTRESSED DEBT INVESTORS CLUB'S TERMS AND CONDITIONS.

  1. DEFINITIONS

    The same Definitions as outlined in the DDIC's Terms 2.01 are applicable to this Policy.

  2. VIOLATION OF POLICY

    Adherence to the Policy's prohibitions is critical. Violation of the Policy will result in a revocation of membership as well as serious legal consequences.

  3. THE SECURITIES EXCHANGE ACT OF 1934

    The Securities Exchange Act of 1934 prohibits fraud in connection with the purchase or sale of a security. Insider trading and illegal tipping are versions of securities fraud. Our procedures are intended to protect our Members and Guests, the mission of the DDIC and to avoid even the suspicion of securities fraud.

    1. Insider Trading generally consists of effecting trades in a public company's securities on the basis of material nonpublic information about the company or its securities. This Policy prohibits all forms of illegal trading and applies to all Members and Guests.
    2. Illegal Tipping involves the passing material nonpublic information to others. This Policy prohibits all forms of illegal tipping and applies to all Members and Guests.
  4. THE FINANCIAL INDUSTRY REGULATORY AUTHORITY

    The DDIC requires all of its Members and Guests to fully comply with The Financial Industry Regulatory Authority (FIRA), which oversees brokerage firms, registered investment advisors and other financial advisors. All Members and Guests are responsible for understanding the regulations imposed by the FIRA and to abide by these regulations.

    The Owners do not condone, encourage or support our Members and Guests in violating the regulations imposed by the FIRA or by our Members' and Guests' firms. The Owners will not be liable for any such violation of policy.

  5. SECURITIES EXCHANGE REGULATIONS

    The Owners require all Members and Guests to strictly adhere to the regulations of the U.S. Securities and Exchange Commission and any rules of any securities exchange, including without limitation, the New York Stock Exchange, the American Stock Exchange or the Nasdaq Stock Market.

  6. MEMBER FIRM POLICIES

    All Members and Guests must comply with their own firm's compliance policies and procedures. Such policies and procedures may affect the timing of the posting or updating of information, may require pre-approval of any posting, may prohibit certain specific information being disclosed, may require specific additional disclosures. The Owners are not responsible for the compliance of Members, Guests or firms with applicable law.

  7. VIOLATION OF LAW

    While the Owners have expressly outlined particular regulations and rules set forth in various securities acts, regulations, authorities and commissions, Members and Guests of the DDIC are not limited to only following these authorities. Violation of any local, state, national or international, law regulation or court order will not be tolerated.

    The Policy has been implemented to help ensure that all Members and Guests comply with global regulations barring the misuse of confidential information, insider dealing and other related forms of securities fraud.

  8. MEMBER POSTED CONTENT

    In furtherance of our Terms 6.04, you may only post content owned by you. You assume all risk and responsibility for the content you post in ensuring it complies not only with this Policy but also the various regulations discussed above.

  9. NON-PUBLIC INFORMATION

    Many Members and Guests may base their research and investment decisions and subsequent posts to the DDIC upon publicly available information. However, it may be common for Members and Guests to be offered material nonpublic information concerning investment opportunities by issuers and dealers who are legally marketing new issues, secondary offerings, block trades etc., while Members and Guests may be permitted to evaluate confidential information about such opportunities from time to time, they are not permitted to publish such information to the DDIC. To do so would be subject such member to the consequences outlined in item 2.

  10. DISCLOSURE AND MATERIAL RELATIONSHIPS

    Members and Guests may not write about a security with the intention to boost (or reduce) the value of that security. If you intend to head your own advice (i.e. buy or sell a publicly-traded security) you must disclose this in your post.

    Material relationships exist. The Owners believe in full disclosure. Members and Guests must agree to disclose any material relationships with companies or parties where the Member or Guest stands to gain in any way from the viewpoint they have outlined. For example, if you are writing about a company that you work for, you better disclose it.

  11. WE ARE NOT ADVISORS

    The Owners do not provide any investment advice. The goal of the Owners is to enable like-minded professionals to share their investment ideas.

  12. MANDATORY NOTIFICATION OF LEGAL COMPLIANCE

    Members or Guests who believe that another Member or Guest is in violation of this Policy must email hunter@distressed-debt-investing.com immediately without notifying any other Member or Guest. We will investigate the complaint and if we discover that the Member or Guest is in violation, the Member or Guest will be terminated.