Retail Customer Disclosures - SEC Regulation Best Interest Disclosures (Reg BI)
On June 5, 2019, the SEC adopted Regulation Best Interest (Reg BI) under the Securities Exchange Act of 1934. Reg BI establishes a “best interest” standard of conduct for broker-dealers and associated persons when they make a recommendation to a retail customer of any securities transaction or investment strategy involving securities. Reg BI is effective as of June 30th, 2020. Odeon is happy to provide it's retail customers with the following information as required under Reg BI.
Please view Odeon's Customer Relationshp Summary (Form CRS) HERE.
Please view Odeon's Customer Disclosure Brochure HERE.
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Odeon Capital Group requires Research Analysts to certify the views expressed in research reports accurately reflect their personal views about subject companies and their securities. They also certify that they have not, will not, nor are they presently receiving direct and/or indirect compensation in exchange for any specific recommendation in a report. In addition, analysts will certify that they have not received compensation from any subject company in the last 12 months.
|Buy||Anticipated total return of 10%+ over the next 12 months including dividend payments and/or the ability to perform better than the leading stock market averages or stocks within its particular industry sector.|
|Hold||Anticipated trading levels at or near the current price and generally in line with the leading market averages and/or will perform less well than higher rated companies within its peer group.|
|Sell||Anticipated depreciation of 10% or more in price within the next 12 months, due to fundamental weakness perceived in the company or for valuation reasons and/or are expected to perform significantly worse than equities within the peer group.|
|No Rating||The security is not rated at this time.|
|Hedge||A combination of being long one security and short another.|
*Definitions of Ratings Revised as of May 7th, 2013.
An equity analyst or a member of its household may not purchase the securities of a subject company 30 days before or 5 days after the issuance of the research analyst’s report or a change in ratings or price targets, trade inconsistent with the views expressed by the research analyst, and all transactions in a research analyst's personal trading account must be pre-approved. Neither the research analyst nor any member of his/her household may own any of the securities of the subject company including any options, rights, warrants, futures or long or short positions. An equity analyst may not trade contrary to his/her own recommendation in a research report. Neither a research analyst nor any member of his/her household may own 1% or more of any of the securities of the subject company based upon the same standards used to compute beneficial ownership for the purpose of reporting requirements under Section 13(d) of the Securities Act of 1934, as amended. Neither a research analyst or household member may be an officer, director, or advisory board member of the subject company. A research analyst may not make a public appearance in front of more than 15 persons to discuss the subject company and may not know or have reason to know at the time of this publication of any other material conflict of interest.
Receipt of Compensation
Receipt of Compensation: The research analysts at the firm do not receive any compensation based on investment banking revenues and may be paid a bonus based upon the overall profitability of the firm.
This research report contains technical analysis which only takes into account historical price performance and it is not an analysis of fundamental factors or other price/risk indicators. When making an investment decision technical analysis alone should not be the only factor to take into consideration. Any price target or recommendation contained in this report based soley on technical analysis is valid as of the date of this publication only and the analyst’s “coverage” of the securities referenced begins and ends the same day. The research analyst welcomes and encourages any comments or questions with regard to this research report.
Our research products are intended for institutional investors and are not subject to all of the independence and disclosure standards applicable to research reports prepared for retail investors. If you do not contact us and request to be removed from our research distributions, we will reasonably conclude that you have consented to receiving institutional research products, and that you are a Qualified Institutional Buyer (QIB) or acting on behalf of a QIB.
Other Additional Disclosures
The firm does not make markets in any securities whatsoever. The firm buys or sells securities for its own account. The firm buys or sells securities on a principal basis with customers. The firm’s employees who are not equity research analysts may buy or sell securities. Although the statements of fact in this report have been obtained from and are based upon outside sources that the firm believes to be reliable, the firm does not guarantee the accuracy or completeness of material contained in this report. Any such estimates or forecasts contained in this report may not be met. Past performance is not an indication of future results. Calculations of price targets are based on a combination of one or more methodologies generally accepted among financial analysts, including but not limited to, analysis of multiples and/or discounted cash flows (whether whole or in part), or any other method which may be applied. Rating, target price and price history information on the subject company (ies) in this report is available upon request. To receive any additional information upon which this report is based this information please contact 212-257-6970, or write to Research Production Department, Odeon Capital Group LLC, 750 Lexington Avenue, 27th fl. New York, New York 10022.
Odeon Capital Group LLC is a U.S. registered broker-dealer and member of FINRA, SIPC and MSRB. This report is prepared for general circulation. The information herein does not constitute a solicitation of an offer to buy or an offer to sell any security nor is it intended to be a complete summary or statement of all available data. This report is not produced based on any individual persons or entities investment objectives or financial situation and opinions expressed by the analyst are subject to change without notice. This report is not provided to any particular individual with a view toward their individual circumstances. Investors should consider this report as only a single factor in making an investment decision. As with any transaction having tax implications, investors should consult with their tax advisor before making investment decisions designed to generate tax benefits. As a matter of policy the firm does not offer tax advice and nothing herein should be construed as offering such advice. The securities mentioned in this report are highly speculative and involve a high degree of risk. Securities prices fluctuate and investors may receive back less than originally invested and are not guaranteed. International securities involve additional risks such as currency fluctuations, differing financial accounting standards, and possible political and economic instability. Small-cap stocks generally involve greater risks. Dividends are not guaranteed and will fluctuate. The securities recommended, offered, or sold by the firm, are not insured by the Federal Deposit Insurance Corporation, are not deposits or other obligations of any insured depository institution, and are subject to risks, including the possible loss of principal amount invested. Any opinions, estimates or projections expressed in this report may assume some economic industry and political considerations and constitute current opinions, at the time of issuance, and are subject to change. No part of this document may be copied, photocopied, or duplicated in any form or other means redistributed or quoted without the prior written consent of the firm. This report and its contents are the property Odeon Capital Group LLC and are protected by applicable copyright, trade secret or other intellectual property laws (of the United States and other countries). United States law, 17 U.S.C. Sec.501 et seq, provides for civil and criminal penalties for copyright infringement.
Research Ratings History Search
Disclosures to Customers
Please view our Customer Disclosure Brochure HERE.
Business Continuity Plan
Please view our Business Continuity Plan Notice HERE.
Rule 605 Disclosure
SEC Rule 605 requires certain FINRA member firms to report to FINRA certain order execution information for listed equity securities. Odeon Capital Group generally reports fewer than 200 transactions per trading day in listed equity securities. Accordingly, the firm is not required to report pursuant to Rule 605. If and when the Firm is required to provide Rule 605 reports, such reports will be posted at www.odeoncap.com/legal.
Rule 606 Reports
In Accordance with SEC Rule 606 Odeon Capital Group is providing its customers with this annual notice regarding a customer’s right to information concerning the routing of their orders for execution.
Odeon Capital Group is required to publish quarterly statistics regarding its customer agency order routing practices. The purpose of the report is to provide the public with information on how broker-dealers route their customers’ orders, to enable customers (and others) to evaluate order routing practices. The Rule was adopted by the SEC to enhance market transparency and foster competition among market participants. This information is available on the internet at the following link and in hard copy for those who do not have access to the internet. The report is published by the end of the month following the calendar quarter reported.
In accordance with U.S. Securities and Exchange Commission (SEC) Rule 606, Odeon Capital Group is publishing statistical information about our routing practices for Held non-directed orders in NMS equity securities and options.
U.S. Securities and Exchange Commission (SEC) Rule 606(a) requires all brokerage firms to make publicly available quarterly reports, broken down by calendar month, containing certain required statistical information regarding the routing of held, non-directed customer orders in Regulation NMS stocks and listed options.
The report contains a section for Regulation NMS stocks (separated by securities that are included in the S&P 500 Index as of the first day of the quarter and other Non-S&P 500 stocks) and a separate section for listed options. For each section, the report identifies the venues to which NS routed the relevant orders and, for each venue, the required statistical information broken down by order type (i.e., market order, marketable limit order, non-marketable limit order and other orders). Each section of the report also contains information regarding the material aspects of NS’s relationship, if any, with each venue. Odeon Capital Group is publishing such quarterly report in accordance with Rule 606(a), and will keep the report publicly available for a period of three (3) years.
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