Investor Protection Principles

BTIG LLC has adopted the following principles to eliminate the potential conflicts of interest that may arise out of a relationship between our Investment Banking and Research Departments. They are as follows:

  • There is no direct link between compensation for analysts and investment banking;
  • BTIG Research Analysts are not compensated for a specific investment banking services transaction;
  • A research principal approves all recommendations;
  • Investment banking has no input into analyst compensation;
  • Discontinuation of coverage is disclosed as well as the rationale for such termination;
  • Research reports disclose whether the firm has received or is entitled to receive compensation from a covered company over the past 12 months; and
  • This process is monitored to ensure compliance with these principles.

1 FINRA Rule 2124 defines a “net” transaction as a principal transaction in which a market maker, after receiving an order to buy (sell) an equity security, purchases (sells) the equity security at one price (from (to) another broker/dealer or customer) and then sell to (buys from) the customer at a different price. 2 FINRA Rule 4512© defines the term “institutional account” as; (A) a bank, savings and loan association, insurance company, or registered investment company; (B) an investment advisor registered either with the Securities and Exchange Commission under Section 203 of the Investment Advisors Act of 1940 or with a state securities commission (or any agency or office performing like functions), or; (C) any other entity (whether a natural person, partnership, trust, otherwise) with total assets of at least $50 million.