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PeakBot Partner Conduct Policy

Effective Date: May 28th, 2026

This policy is subject to change. All partners will be notified when changes take place.

This policy is not legal advice. It sets out the standards PeakBot requires our partners to operate under. Partners are responsible for obtaining their own legal counsel to ensure their conduct complies with applicable law.

Purpose

This policy establishes the standards that all PeakBot partners must follow when operating on the PeakBot platform. PeakBot operates as a technology platform connecting independent partners to subscribers through broker integrations. Partners are responsible for their own marketing, pricing, and subscriber relationships. This policy defines the conduct standards required of all partners and the consequences of non-compliance.

Application

This policy applies to all current and prospective PeakBot partners. Each partner acknowledges this policy as part of their partner agreement. Existing partners must come into compliance with this policy within five (5) business days of receiving this notice.

Partner Responsibility

Partners are solely responsible for ensuring their own compliance with this policy and with all applicable laws and regulations. PeakBot does not actively monitor partner conduct. PeakBot will investigate and enforce this policy when violations are brought to PeakBot's attention through subscriber complaints, broker notifications, regulatory inquiries, or other credible reports.

Section 1: Marketing and Public Representations

1.1 Performance Claims

Partners may not:

  • Make any untrue statement of material fact or omit to state any material fact that is necessary to make any statement not misleading (a material fact would be any fact that an actual or prospective subscriber would consider important in engaging or continuing to engage with a Partner)
  • Guarantee specific investment returns or account growth
  • Project specific future returns for any subscriber or group of subscribers
  • Claim that subscribers will achieve any specific financial outcome
  • Make statements that imply consistent profitability or freedom from loss
  • Market former strategies that they will not be using as a part of their service

Examples of prohibited statements:

The following examples are not intended to be exhaustive.

  • "You can turn $10,000 into $100,000 within a year."
  • "I averaged 400% last quarter and subscribers can expect the same."
  • "Subscribers are seeing 6-figure passive income."
  • "Take a look at my past results, that should give you confidence in the strategy."
  • "I'll get your account to where you want it to be."
  • "You'll make your money back in the first month."

Partners may present historical performance only if accompanied by:

  • Clear disclosure of the time period covered
  • Risk disclaimers including the possibility of loss
  • Methodology disclosure including fees and trading costs
  • Disclaimer that past performance does not guarantee future results
  • Disclosure that the performance was produced entirely by the strategy they are allowing others to automate

1.2 Registration and Compliance Claims

  • Claim to be an investment adviser or investment professional unless properly registered with the SEC or applicable state regulator
  • Claim to be a commodity trading adviser or commodity adviser without registration with the Commodity Futures Trading Commission
  • Claim to be SEC compliant, SEC approved, SEC endorsed, or compliant with any federal or state regulatory body
  • Claim any regulatory status the partner does not actually hold
  • "We are SEC compliant."
  • "We are SEC registered."
  • "Our software is approved by the SEC."
  • "Tradier wouldn't work with us if we weren't legitimate."
  • "We're allowed to charge these fees because PeakBot has the proper structure."

1.3 PeakBot Relationship

Partners must accurately describe their relationship with PeakBot. Partners may not represent themselves as PeakBot employees, agents, or authorized representatives. Partners may not claim PeakBot endorsement of their specific service, performance, or conduct.

  • "PeakBot endorses my service."
  • "PeakBot approved my pricing structure."
  • "PeakBot covers my activity."
  • "PeakBot guarantees execution of my trades."

Examples of acceptable statements (if accurate):

  • "I use PeakBot's platform to deliver automated trading."
  • "PeakBot is the technology provider for my automation."

1.4 Guaranteed Outcome Statements

Partners may not make statements that imply or guarantee subscriber outcomes, even in informal or conversational form.

  • "We don't lose."
  • "This is a no-brainer."
  • "You'd be crazy not to subscribe."
  • "Risk-free returns."
  • "Guaranteed monthly income."
  • "You'll profit from this."

1.5 Testimonials and Endorsements

Partners may use subscriber testimonials only if:

  • The testimonial is genuine and from an actual subscriber
  • The testimonial is accompanied by a clear disclaimer that individual results are not typical and not guaranteed
  • Any compensation, free service, or benefit provided to the person giving the testimonial is disclosed
  • The testimonial does not imply guaranteed outcomes for prospective subscribers

Partners may not cherry-pick the best subscriber results and present them as representative of typical subscriber experience without having a disclaimer that their performance is not typical or without directing the prospective subscriber to a site containing all subscriber testimonials and reviews.

1.6 General Marketing Conduct

Partners may not engage in marketing that is false, misleading, deceptive, or fraudulent. This includes but is not limited to:

  • Misrepresenting the nature of the service being offered
  • Misrepresenting the partner's experience, credentials, or qualifications
  • Cherry-picking trades or time periods to imply better performance than actual
  • Creating fake reviews or fabricated social proof

Section 2: Pricing Standards

2.1 Required Pricing Structure

Partners must:

  • Charge a flat subscription fee that is the same for all subscribers
  • Use subscription pricing (monthly or annual)

2.2 Prohibited Pricing Practices

  • Scale fees based on subscriber account size or assets under management
  • Charge fees based on subscriber trading performance or returns
  • Engage in any pricing practices that would constitute a bait and switch or similar fraudulent business practice
  • Negotiate individualized pricing with subscribers based on their financial situation
  • Change pricing for existing subscribers without proper notice and consent

We encourage you to publish your pricing publicly to potentially avoid any issues with the matters listed above.

Examples of prohibited pricing practices:

  • "It's $5,000 for subscribers with a $10,000 account, $15,000 for subscribers with a $50,000 account."
  • "I'll discount $1,000 for you because you only have $5,000 to invest."
  • Requiring existing subscribers to pay additional fees mid-subscription to maintain access

Partners may offer different service tiers, but tiers must be differentiated by service features (additional automatable capital, additional access, additional support) rather than by the subscriber's overall account size.

2.3 Pricing Transparency

All pricing must be clearly disclosed before subscription. Hidden fees, undisclosed charges, or pricing structures that are not apparent at the point of subscription are prohibited.

Section 3: Content and Communication Standards

3.1 Publishing Cadence

Partners must publish content regularly, rather than communicating only when specific trades or market opportunities arise. Communications must be educational, analytical, or informational rather than purely directive.

3.2 General and Impersonal Communication

Partners must communicate with subscribers as a group rather than providing individualized advice. Partners may not:

  • Tailor recommendations to specific subscriber portfolios, account sizes, or financial situations
  • Provide model portfolios that differ based on certain financial situations
  • Provide individualized portfolio advice through any channel
  • Hold one-on-one consultations about specific subscriber trades or investment decisions as they relate to automated trades
  • Adjust trade recommendations based on individual subscriber characteristics

Examples of prohibited communications:

  • "For your $50,000 account, here's what you should do."
  • "Given your retirement timeline, you should adjust your positions to..."
  • "DM me your portfolio and I'll tell you what to change."
  • "Send me your account details and I'll customize the strategy for you."
  • "What is your risk tolerance?"

If a subscriber requests personalized advice, partners must decline and offer only general commentary applicable to all subscribers.

3.3 Subscriber Interaction

Partners may engage with subscribers in community settings (Discord, group chats, livestreams, group emails) provided that all such engagement is general in nature. Partners may not establish individual advisory relationships with subscribers.

3.4 Discretionary Authority

Partners may not accept discretionary authority over subscriber accounts. Partners may not request or accept account credentials, login information, or any form of direct access to subscriber brokerage accounts. All trade execution must flow through PeakBot's platform integration.

Section 4: Required Disclosures

4.1 Service Description

Partners must accurately describe the nature of their service. Partners providing trade signals that are automatically placed must clearly disclose:

  • The automated nature of trade execution
  • That subscribers do not approve individual trades, but they do approve the tickers they want automated and the budget to automate for each ticker
  • That trades will be placed regardless of subscriber availability or attention
  • Subscribers will integrate their personal brokerage account via API for automated trades
  • That subscribers retain ultimate responsibility for their accounts

Section 5: Subscriber Protection

5.1 Subscriber Communications

Partners must respond to subscriber inquiries and complaints in good faith. Partners may not retaliate against subscribers who raise concerns.

5.2 Refunds and Cancellations

Partners must honor subscription terms as published. Partners must process cancellation requests in accordance with stated refund policies. Partners may not impose hidden barriers, fees, or requirements that prevent subscribers from cancelling.

Section 6: Compliance with Law

Partners are solely responsible for compliance with all applicable laws and regulations, including but not limited to:

  • The Investment Advisers Act of 1940 and its exemptions
  • The Commodity Exchange Act of 1936 and its exemptions
  • State investment adviser registration requirements
  • FTC regulations regarding marketing, testimonials, and endorsements
  • State consumer protection laws
  • Federal and state securities registration and anti-fraud provisions

Partners are responsible for determining whether their activities require registration as an investment adviser, broker-dealer, commodity trading adviser, or other regulated entity. PeakBot does not provide legal advice to partners. Partners are responsible for obtaining their own legal counsel to ensure their conduct complies with applicable law.

Section 7: Enforcement

7.1 PeakBot's Role

PeakBot is a technology platform and does not actively monitor partner conduct. PeakBot will investigate alleged violations of this policy when brought to its attention through:

  • Subscriber complaints submitted to PeakBot
  • Broker partner notifications
  • Regulatory inquiries
  • Other credible reports from any source

7.2 Investigation Process

When PeakBot becomes aware of a potential violation, PeakBot will:

  1. Review the alleged violation against this policy
  2. Notify the partner of the alleged violation
  3. Provide the partner with an opportunity to respond
  4. Determine whether a violation has occurred
  5. Take corrective action is necessary

7.3 Grace Period for Cure

Upon notification of a violation, partners will be given a five (5) business day grace period to cure the violation. During this period, the partner must:

  • Acknowledge receipt of the violation notice
  • Take corrective action to address the violation
  • Provide PeakBot with evidence of the corrective action

7.4 Failure to Cure

If a partner fails to cure a violation within the five business day grace period, PeakBot may:

  • Suspend the partner's access to the platform, including their ability to place trades
  • Withhold payments due to the partner
  • Terminate the partner agreement
  • Pursue any other remedies available under the partner agreement or applicable law

7.5 Immediate Termination

PeakBot reserves the right to terminate a partner immediately, without the five business day grace period, in cases involving:

  • Fraud or intentional misrepresentation
  • Conduct that creates regulatory exposure for PeakBot
  • Conduct that threatens broker integration relationships
  • Repeated violations of this policy
  • Failure to cooperate with PeakBot's investigation

7.6 No Waiver

PeakBot's decision not to enforce a particular violation does not constitute a waiver of PeakBot's right to enforce this policy in the future. Past tolerance of conduct does not create a right to continue that conduct.

Section 8: Updates to This Policy

PeakBot may update this policy from time to time. Partners will be notified of material changes. Continued operation on the PeakBot platform after notification of policy updates constitutes acceptance of the updated policy.

Section 9: Acknowledgment

By operating on the PeakBot platform, each partner acknowledges that:

  • They have read and understood this policy
  • They are responsible for their own compliance with this policy and applicable law
  • They will operate within the requirements of this policy
  • They understand the consequences of non-compliance
  • They have obtained or had the opportunity to obtain their own legal counsel regarding their conduct

Questions about this policy should be directed to: [email protected]