Disclosure & Compensation Policy
Last updated: October 17, 2026
Trust is the product. This policy explains how we handle our analyst's own holdings, personal trading and any compensation from companies, so you can always judge our research with full information.
1. Independent membership research
Our membership research is independent. Companies cannot pay to be included in our membership research, model portfolios or watchlists, and cannot pay to influence what we write about them.
2. Disclosure of the analyst's holdings
Our Chief Analyst, Daniel Wilhelmi, invests his own money and may hold positions in securities he discusses. When we publish research on a security, we disclose whether he holds a position in it at the time of publication. Material changes to a disclosed position are reflected in subsequent member publications.
3. Personal trading rules
To avoid conflicts of interest, our analyst follows these rules:
- No trading around publications: he does not buy or sell a security within 48 hours before or 48 hours after we publish research, a portfolio update or a video that discusses that security.
- No trading against published views: he does not trade in the opposite direction of a current published view (for example, selling a position while the published view is to hold or add) without first disclosing the change to members.
- Members first: changes to the model portfolio are published to members before, never after, the analyst acts on the same change in his personal account.
4. Compensation from companies
If we or our analyst ever receive compensation from a company — directly or indirectly, in cash, shares or otherwise — in connection with any content about that company (for example a sponsored video or interview), that content will be clearly labeled as sponsored, and the nature and amount of the compensation, and who paid it, will be disclosed with the content, consistent with Section 17(b) of the U.S. Securities Act of 1933. Sponsored content is never part of the membership research or model portfolio.
5. Travel, conferences and site visits
Our analyst attends industry conferences and visits company sites. If a company pays for travel or accommodation for a site visit, this will be disclosed in any related publication.
6. Affiliate and referral links
Any affiliate or referral link we publish will be clearly labeled as such.
7. Questions
If you have a question about a specific disclosure, contact us at support@bullmarketlifestyle.com.