Compliance
We’re a publication. We tell you what changed.
Drift Brief operates as a publication of general circulation under Section 202(a)(11)(D) of the Investment Advisers Act of 1940 — the same publisher’s exemption that covers Substack financial newsletters, Seeking Alpha, the Wall Street Journal, and Morningstar. Lowe v. SEC (1985) is the case that locked this posture in.
Four commitments
The exemption holds because we keep four lines bright.
- Impersonal content. Every Pro subscriber sees the same findings, the same severity calls, the same digest content. We don’t tailor editorial output to your personal portfolio, your risk tolerance, your tax situation, or your trading style.
- Bona fide + regular publication. Real cadence (Friday digest), real corrections inbox (corrections@driftbrief.com), real masthead, real archive. Not a one-off newsletter dressed up as a publication.
- General circulation. Open to public subscription at advertised pricing. Not directed at named individuals or accredited-only.
- No personalized recommendations. We never tell you to buy, sell, or hold any security. We never set price targets. We never claim to know what your portfolio should do.
What we will not say
- “X is a buy” or “sell X” or “hold X”.
- Price targets, fair-value estimates, return forecasts.
- “You should” anything related to investment decisions.
- Bullish / bearish framings of specific securities.
- Claims about Drift users’ own performance — no “X% of our readers predicted correctly”, ever.
The chat (Pro+) is guarded by a compliance filter that blocks responses containing advisory phrases. Findings and the Friday digest go through editorial review before publication. The audit trail (rag_query_log) captures every chat exchange for after-the-fact review.
What we will say
- What changed in a filing. Drift’s core output: new Risk Factor language, rewritten MD&A, removed disclosures, added material events.
- What the filing actually said. Cited to the source paragraph in EDGAR, every time.
- Severity of the disclosure change. Editorial label, not an investment rating. Critical means materially new or rewritten language — not “you should sell.”
- Adjacent context. The price of the stock around the filing date, the sector ETF, macro indicators, relevant commodity prices, public geopolitical events. All observational; never causal.
- Plain-English explanations. When a filing uses jargon, we translate. When the implication isn’t obvious, we explain why a reader might care — without prescribing action.
Your data, your privacy
- Your companies are yours. We don’t show them to other users.
- Your prediction journal is private. We don’t grade it, share it, or aggregate it. Ever.
- Your annotations are private. Same posture.
- We log chat queries for audit (compliance defense) and product analytics. Aggregate query patterns may inform our editorial direction; specific queries are not surfaced to other users.
- Account deletion (in Settings → Danger zone) wipes your companies, journal entries, annotations, and finding read-state. The chat audit log is retained (including the account identifier) as our compliance / legal-defense record — see the privacy policy for that one exception.
Corrections + concerns
Drift Brief is a small operation. We will make mistakes. If you find:
- A finding that misreads a filing — email corrections@driftbrief.com.
- Chat output that crosses the advisory line — email compliance@driftbrief.com with the conversation URL.
- A privacy concern — email privacy@driftbrief.com.
We read every report. Corrections post within 24 hours when warranted; retractions when the underlying claim was wrong. Compliance concerns are escalated immediately and reviewed before the chat surface continues serving the affected pattern.
Not investment advice
Nothing on Drift Brief is investment advice. The information we surface is intended to support your own analysis, not to replace it. Past disclosures are not predictive of future outcomes. Drift Brief is not a registered investment adviser.