Alan Brochstein's Personal Disclosure

Updated 08/14/19

I receive questions occasionally and want to create this document, which is available to the public, to address any concerns about potential conflicts of interest as it relates to 420 Investor. I earned the designation of Chartered Financial Analyst (CFA) in 1997 and am committed to transparency and displaying the highest levels of integrity. I adhere to the CFA Institute's Code of Ethics and Standards of Professional Conduct.

With respect to personal trading, I have not ever nor will I invest in publicly-traded cannabis stocks. While this may seem disappointing to some, my intent is to avoid anything that would threaten my objectivity. More importantly, doing so would put me in a position of potentially "front-running" subscribers.

As I have previously indicated, in the event that I enter into any consulting arrangements with private companies, I will disclose the nature and, if possible, the name of any such relationships.

While I have no current arrangements to refer accredited investors to companies seeking capital, I may do so in the future. If so, I will disclose the nature of my compensation.

I have published at Seeking Alpha, where I am typically compensated at a rate of $0.01 per page-view, though there are flat-fee arrangements as well that can range from $150 to $500. SA is a platform that allows individual contributors to publish content - I am in no way an "employee" of SA.

I had consulting relationships with investment management firms, but, at the time, these relationships covered stocks that are entirely outside the cannabis space. Should I provide cannabis-related research to institutional investors in the future, I will disclose it.

I am not a registered investment advisor. In no way should anyone infer that I am providing individual investment advice. 420 Investor is a newsletter, and I am the publisher. I may elect to become a registered investment advisor in the future. At present, I do not touch the assets (securities, cash) of any subscribers, nor do I have any authority to make investment decisions on their behalf.

When I worked with a registered investment advisor, I was registered with FINRA. You could have accessed my report through FINRA's BrokerCheck. As I am no longer governed by FINRA, I am presently shown as "not licensed". I have never been charged with any misdemeanor or felony.

I owned 420 Investor Gear, which was operating as a for-profit business. I received 10% royalty and 5% was allocated to not-for-profits NORML and Marijuana Policy Project. This business is inactive.

I had had an affiliate relationship with Arcview, with the potential to earn commissions on the sale of their Market Research. These are standard terms, and Arcview has several other affiliates. My annual earnings never exceeded $1000. New Cannabis Ventures has also had an affiliate relationship with Arcview, and it had an affiliate relationship with Green Flower Media. Through New Cannabis Ventures, I have a relationship with Benzinga that pays commissions on tickets that we directly sell to its conferences as well as a percentage of all sponsorships of the events.

On May 7th, 2014, I attended the GreenRush Financial Conference in Vancouver. The conference company was owned by Nextgen, a Canadian company that trades with the symbol "N" and in the U.S. as "NXTTF" that has since evolved into Namaste Technologies following a reverse-merger. I received no cash compensation, but the company provided for my flight and hotel (approximately $1200). In March 2017, I flew to Denver to meet with Andy Williams of Medicine Man Technologies (MDCL) to discuss a possible collaboration on a project. The company paid for my airfare, hotel and two meals, with the total expense estimated at less than $1300.

In December 2014, I provided expert testimony for a civil matter involving a publicly-traded company in the cannabis space on behalf of an individual against whom this company has filed a lawsuit. I am prevented from discussing details regarding the matter. Should the trial proceed and my involvement become part of the public record, I will disclose more details.

I am the majority owner of New Cannabis Ventures. This is a financial news site focused on the B2B cannabis industry. We are supported through advertising from privately-held companies and, effective 10/1/16, from a limited number of public companies, for which we are providing "Investor Dashboards". We publish a disclaimer that includes our clients by name. I will disclose this regularly when discussing these companies on 420 Investor. Current companies include 48North, Aurora Cannabis, Canopy Growth, Charlotte's Web, Cresco Labs, DionyMed Brands, Fire & Flower, GABY, Inc, Green Growth Brands, Harvest One, iAnthus Capital, INDIVA, KushCo Holdings (formerly Kush Bottles), Liberty Health, Medicine Man Technology, MediPharm Labs, MPX International, Organigram, Plus Products, Supreme Cannabis, TerrAscend, TILT Holdings, VIVO Cannabis, and Vireo Health. We worked with Australis Capital from 10/30/18-04/29/19. We worked with Canopy Rivers from 09/18/18-02/04/19. We worked with CB2 Insights from 5/14/18 through 6/14/19. We worked with Emblem 12/12/16 through 2/28/19. We worked with Emerald Health from 1/15/17 through 3/31/17. We worked with Green Organic Dutchman from 11/25/16 through 10/10/18. We worked with GrowGeneration from 1/1/17 through 03/31/18. We worked with Khiron from 5/23/18 through 8/22/18. We worked with High Tide from 2/1/19-5/9/19. We worked with Hiku Brands from 7/27/17 through 7/31/18. We worked with MJardin from 11/15/18-05/31/19. We worked with MPX Bioceutical from 06/15/17-01/31/19 .We worked with Organigram from 1/1/17 through 03/31/17. We worked with RavenQuest BioMed from 12/1/17 through 08/31/18. We worked with Generation Alpha (formerly Solis Tek) from 4/16/17 through 10/31/17. We worked with Therapix Biosciences from 3/22/17 through 7/26/17. We worked with Wayland (formerly Maricann) from 4/22/17-4/30/19. We provided Organigram with advertising on our Cannabis Careers page from 5/30/18 through 8/29/18.

Should you have any concerns or questions about my conduct or practices, please contact me.

Posted to 420 Investor on Feb 01, 2014 — 1:02 PM
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