Notice TS cannot buy or sell Neom within 30 days before or after changing their published recommendation since Neom had a market cap less than $300 million.
If I interpret this disclosure correctly, it appeared that he still owned Neom as of October 3, 2006 or was it as of September 5, 2006? 30 days prior to October 6th sell recommendation was September 7th.
Of course, there is the possibility that his personal investment goals and risk tolerance are different and that he continues to hold Neom stock.
Here again is the relevant paragraph from the Changewave Microcap Disclosure:
The Editor has agreed not to buy or sell any of the above-listed securities within a minimum period of five trading days before or after making any new recommendation, or changing their published recommendation, regarding these securities in their Newsletter (calculated from the date the Newsletter featuring such recommendation is first posted on www.changewave.com/microcap or, if such recommendation is made in the applicable telephone hotline, the date the telephone hotline is first made available to subscribers), unless the market capitalization of the security at the close of business on that date is less than $300 million (the current Standard and Poors’ requirement for inclusion in the S&P SmallCap 600 index) in which case, the Editor has agreed to not buy or sell such security within a minimum period of thirty trading days before or after the applicable date. After the expiration of this period of five or thirty trading days, the Editor may hold, buy or sell such securities, and may cease to own any of the securities listed above. Since the Editor’s personal investing goals and risk tolerance may be different from those discussed in the Newsletter and/or circumstances may have changed by the expiration of the five or thirty day restricted period, the investment actions taken by the editor in the accounts the Editor directly or indirectly owns may vary from (and may even be contrary to) the advice and recommendations in the Newsletter.
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