Communication Policy

Purpose

The Policy outlines how RC Brown Capital communicates product information to ensure accuracy, transparency, and regulatory compliance.

Scope

Applies to:

• Investment proposals

• Performance reports

• Marketing materials

• Client statements

• Press releases

• Social media

Communication Principal

Accuracy:

All communications must be factual and not misleading.

Regulatory Compliance:

• All investment marketing must comply with SEC Rules and NAICOM Guidelines

• Disclosures of risks, fees and terms

• Advertising performance returns

Performance Disclosure

All performance data must include material disclaimers to provide clarity regarding historical returns and their relevance (or irrelevance) to guaranteed future returns.

Record Keeping

Copies of public communications shall be retained for a minimum period as required by regulatory requirements.

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