HYPOTHETICAL PERFORMANCE These are paper-trading portfolios. No client money is invested, no orders are routed to any venue, and no result shown here was achieved with real capital. Hypothetical results have inherent limitations and do not reflect the effect of real order flow on price.
Transparent AI Investment Platform
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Disclosures

MAR applies extraterritorially to financial instruments admitted to trading on EU regulated markets, MTFs and OTFs. A large share of US large-caps are admitted on EU MTFs without issuer involvement, so being established in Switzerland does not place this publication outside MAR. This site therefore assumes Article 20 applies and that the producer is an "expert" within Commission Delegated Regulation (EU) 2016/958 Art 1.

Producer

Entity
Transparent AI Investment Platform
Form
unincorporated sole operator — no legal entity has been formed
Jurisdiction
Switzerland
Contact
niek.butera@gmail.com
Natural persons
Niek Christen — Operator

The natural person producing this content is named, with a job title. This is the disclosure MAR Article 2 asks for, and it is published on every page rather than on a legal notice nobody reads.

MAR obligations, article by article

Each is marked satisfied or not. An unmet obligation is stated as unmet rather than described in language that implies otherwise — that is the only version of this page worth publishing.

MAR Art 2 / Delegated Regulation (EU) 2016/958 Art 2satisfied

The identity of the producer: name and job title of all natural persons involved in producing the recommendation, and the name of the legal person responsible.

Art 3 — facts distinguished from interpretationsatisfied

Facts must be clearly distinguished from interpretations, estimates and opinions; all substantially material sources must be indicated; projections and forecasts labelled.

  • Every AI-generated passage carries a banner stating that it is model output, and states how many of its quantitative claims traced back to source data.
  • Every figure on this site carries the licence key of the source it came from; there is no rendering path for a figure without provenance.
  • The complete fact pack given to the model for each decision is published as downloadable JSON with its hash, so a reader can reconstruct exactly what the model saw.
Art 4 — basis of valuation, methodology, assumptionsnot satisfied

A summary of any basis of valuation or methodology and the underlying assumptions; an indication and summary of any change to them; the meaning of any recommendation such as buy, sell or hold; and an appropriate sensitivity analysis.

  • Every mandate is published verbatim as the machine-readable YAML the rule engine actually executes — not a prose summary of it.
  • The execution cost model is published verbatim, with each assumption either sourced or explicitly flagged unsourced.
  • Changes to any rulebook are RULEBOOK_CHANGE events in the same hash chain as trades, with a full diff and a reason. A limit cannot be quietly loosened after a bad quarter.
  • The meaning of each permitted action is published: the AI may only express direction and conviction, never a price, quantity or weight.
Sensitivity analysis — partial. Execution-cost sensitivity across 5 broker profiles (zero_commission_us, swiss_retail, institutional, crypto_retail_punitive, intraday_punitive) is computed and published. Rendering every performance figure under all profiles simultaneously, and a second axis at +/-50% on the spread assumptions, is specified but not yet built. This gap is published rather than omitted.
Art 5 and 6(1) — interests and conflictsnot satisfied

Disclose relationships and circumstances that may reasonably impair objectivity. Experts additionally disclose net long or short positions exceeding 0.5% of an issuer's total issued share capital, holdings by the issuer above 5%, market-making and any service agreement with the issuer.

  • No client money is managed, held or received. There are no clients, no mandates and no power of disposal over anyone's assets.
  • No order is routed to any venue. All trading is on paper.
  • No affiliate link, issuer sponsorship, revenue share, paid placement or payment-for-order-flow arrangement exists with any person connected to any instrument named on this site.
  • No market-making activity and no service agreement with any issuer named on this site.
  • No net position above 0.5% of any issuer's issued share capital is held. The portfolios are hypothetical and hold no instruments in fact.
Gap: A personal-holdings disclosure and a written no-front-running policy with a published trading blackout are specified and not yet built.
Art 6(2) — internal arrangements and information barrierssatisfied

A description of the effective internal organisational and administrative arrangements and of any information barriers set up to prevent and avoid conflicts of interest.

  • The AI layer ranks and explains. It has no field in its output schema in which a price, quantity, weight or limit could be expressed, and a test fails the build if that schema is widened.
  • All sizing, pricing and risk enforcement is deterministic code the model cannot see or influence.
  • The rule engine applies three gates the AI cannot bypass, and every refusal is published with a stable reason code.
  • The decision, the model identity and the hash of its complete input are committed to an append-only hash chain BEFORE the model is called and before any fill price is known.
Art 6(3) — quarterly buy/hold/sell distributiondoes not apply

Investment firms and credit institutions must publish quarterly the proportion of recommendations that are buy, hold or sell over the previous twelve months.

This obligation does not bind a non-firm publisher. It is published regardless: it is the strongest available anti-cherry-picking signal, and it becomes mandatory the moment a bank joint venture exists.

The full disclaimer stack

hypothetical critical

HYPOTHETICAL PERFORMANCE — These are paper-trading portfolios. No client money is invested, no orders are routed to any venue, and no result shown here was achieved with real capital. Hypothetical results have inherent limitations and do not reflect the effect of real order flow on price.

not advice critical

This is not investment advice and not a personal recommendation. Nothing here is tailored to any reader's circumstances, objectives or financial situation. Every visitor sees identical content; there is no questionnaire, no risk profiling and no personalisation of any kind, by design and permanently.

ai generated critical

Portions of this site are generated by a large language model. The model can be wrong, and not every passage is reviewed by a human before publication. Passages that could not be fully traced back to source data are published with that fact stated — they are flagged, not deleted, because hiding the model's mistakes would defeat the purpose of the record.

past performance

Past performance and hypothetical performance are not indicative of future results.

costs

All results are shown after modelled execution costs: spread, market impact, commission, SEC Section 31 fees and FINRA TAF. The complete cost model and every assumption in it are published.

no execution

No brokerage account is connected, no order is transmitted to any venue, and no reader can trade through this site.

jurisdiction

Published from Switzerland. Nothing here is an offer or solicitation in any jurisdiction where that would be unlawful.

Structural choices that are permanent

How permanence is enforced

This is a map with sources, not legal advice, and nothing here substitutes for Swiss and US counsel.

Follow the record.Every decision, fill and refusal, as it is published — including the ones that lose money.Join on Telegram →

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