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Disclaimer Robert Selzer and Small Cap Picayune, LLC use the “publisher’s exclusion” from the definition of “investment adviser” as provided under Section 202(a)(11) of the Investment Advisers Act of 1940 and corresponding state securities laws. To the extent any of the content published on the website including e-mail transmissions, faxes, recorded voice messages, and any other associated messages/media (hereinafter collectively referred to as “Information”) may be deemed to be investment advice, such information is impersonal and not tailored to the investment needs of any specific person. The information contained within this Web site, including e-mail transmissions, faxes, recorded voice messages, and any other associated messages/media (hereinafter collectively referred to as “Information”) is provided for informational and educational purposes only. The Information should not be construed as investment/trading advice and is not meant to be a solicitation or recommendation to buy, sell, or hold any securities mentioned. Small Cap Picayune holds itself as “the publisher of bona fide newspaper, news magazine or business or financial publication of general and regular circulation.” We believe this to be the case because we do not render specific advice to specific clients based on his or her investment situation. Section 401(f) of the Uniform Securities Act, upon which the majority of state securities laws are based, similarly excludes from the definition of investment adviser “a publisher of any bona fide newspaper, news column, newsletter, news magazine, or business or financial publication or service, whether communicated in hard copy form, or by electronic means, or otherwise, that does not consist of the rendering of advice on the basis of the specific investment situation of each client.” Since a bona fide newsletter publisher is not an investment adviser, registration as such is not required. However, Section 17(b) of the Securities Act of 1933 (15 U.S.C. 77q(b)) prohibits any person from publishing, giving publicity to, or circulating any notice, circular, advertisement, newspaper, article, letter, investment service or communication which describes a security for a consideration received or to be received, directly or indirectly, from an issuer, underwriter or dealer, without fully disclosing the receipt, whether past or prospective, of such consideration and the amount thereof.
Small Cap Picayune, LLC 641 Lexington Avenue, Suite 1304, NY, NY 10022 212.706.0664 robert.selzer@smallcappicayune.com