Disclosures and terms

Disclosures.

Standard disclosure

General research and statistical measurement. Not tailored to the recipient's investment objectives, financial situation, or needs. Not investment advice, a recommendation, or an offer to buy or sell any security. Marnello LLC is not a registered investment adviser and does not manage client assets or exercise discretion over any account.

Nature of the service

Marnello LLC provides quantitative research, statistical measurement, performance attribution, and risk reporting to professional and institutional recipients. Deliverables describe historical characteristics of securities, portfolios, factors, or return series. They contain no ratings, price targets, or position recommendations, and express no opinion on the advisability of investing in, purchasing, or selling any security.

No personalization

No Marnello product accepts a recipient's risk tolerance, investment objectives, time horizon, or financial circumstances as an input. Holdings submitted for analysis are processed as a data set to be measured. Nothing in any deliverable should be read as a statement about the suitability of any holding or portfolio for any person.

No custody, no discretion

Marnello LLC does not hold client assets, does not have trading authority over any account, and does not execute transactions. Programmatic access, where provided, is read-only.

Fees

All fees are fixed subscription fees, fixed per-file fees, fixed licence fees, or fixed project fees. No fee is based on the performance of any account or security.

Historical results

Backtested and simulated results are hypothetical, are computed from historical data under stated assumptions, and do not represent the results of actual trading. Past characteristics do not forecast future behaviour. Validation records, including out-of-sample results and transaction cost sensitivity, accompany every published factor and describe limitations rather than conceal them.

Client data

Holdings submitted for analysis are processed under a defined retention policy and are not used for any purpose other than producing the requested deliverable. Marnello LLC holds no account credentials or account access.

Use of deliverables by recipients

Recipients are solely responsible for their own regulatory obligations, including any obligation to substantiate advertising claims, and for how Marnello output is presented to their clients or regulators. Deliverables are licensed for the recipient's internal use and may not be redistributed or resold without written consent.

Entity

Marnello LLC is a California limited liability company with its principal office in Los Angeles County, California. Marnello LLC is not registered as an investment adviser with the U.S. Securities and Exchange Commission or any state securities authority.