FAQ:Investor Relations Professional

What is an IRP?

This is an acronym for an Investor Relations Professional. IRPs are users who provide investor awareness, investor relations, or any other compensated promotional service or activity relating to a publicly traded stock. IRPs may be compensated by either the public company to which they are providing publicity or by some other interested party, and include persons who are contracted by other IRPs. iHub considers users who make posts (both public and private) subject to Section 17(b) of the Securities Act of 1933 to be an IRP. The relevant text of Rule 17(b) (page 56) is as follows:

   It shall be unlawful for any person, by the use of any means or instruments of transportation or communication in interstate commerce or by the use of the mails, to publish, give publicity to, or circulate any notice, circular, advertisement, newspaper, article, letter, investment service, or communication which, though not purporting to offer a security for sale, describes such security for a consideration received or to be received, directly or indirectly, from an issuer, underwriter, or dealer, without fully disclosing the receipt, whether past or prospective, of such consideration and the amount thereof.More information about what qualifies someone as an IRP can be found here.

What is a Commercial User?

Commercial Users are permitted to have a dedicated message board where they can post links to their website as long as the content on the remote website comnplies with iHub's Terms of Service. The commercial user can then link to posts on their board from other iHub message boards as long as the ultimate content is on-topic. These users cannot post links on other iHub boards that link directly to their website.

• All Commercials Users pay a fee for their posting privileges. The base fee is $95 per month per user account (auto-recurring). This fee is paid in addition to any other base membership or ADVFN streaming data subscription. Discounts may be available for multi-month subscriptions. Activation of an IRP subscription:

• Allows their personalized Disclosure/Disclaimer page, if they elect to have one, to become visible to other users. This allows IRPs to meet their legally mandated disclosure requirements, and to present their professional credentials and associations.

• Automatically includes a link to their Disclosure/Disclaimer page on each post. They can choose to omit the link on posts where it is not required.

• Enables an icon in the Member's profile indicating their Commercial/IRP status and leading to their Disclosure/Disclaimer pages.

• Provides visibility to iHub users when content is being provided by a Commercial/IRP poster.

Any registered member can activate and edit their own Disclosure/Disclaimer page at any time from their My Account screen. Each user's Disclosure/Disclaimer page will not become visible to other users until they become activated with an initial Commercial subscription. Once activated, the Disclosure/Disclaimer page will remain publicly visible. However; there must be an active Commercial/IRP subscription in force in order for the Member to edit their Disclosure/Disclaimer page and to include the link to their Disclosure/Disclaimer on new posts.

I no longer do promotions but have in the past. Do I need to sign up for this?

If you are required to make disclosures under Rule 17(b), then you meet iHub's requirements to become an IRP. When and whether you are required by law to disclose is something that should be discussed with your legal counsel.

This is bull! I shouldn't have to pay more than anyone else because I'm creating market awareness for a company! I'm helping the people on your site by promoting this company!

You are using iHub for commercial purposes. The modest fee allows you to use the site and to make your legally required disclosures. You cannot post on iHub for purposes of fulfilling your compensated awareness campaign without being an IRP.

I'm a promoter but refuse to pay the additional fees. I just won't talk about any of my stocks on iHub.

No disclaimers other than the ones in the IRP pages will be allowed. If you choose to bypass the system and post about a company you are being compensated to promote, you will likely receive a long suspension at minimum.

I'm an IRP but the disclaimer is not showing up in my posts.

Below the box where you compose your post, there is a box that you need to check to have the disclaimer show up in that message.

Yikes! I'm an IRP and forgot to check the box for my disclaimer! When I go to Edit it won't allow me to add it! I legally have to have this on the post. What now?

Within in the edit period, you can add a link to your disclosure page in the content of the message. Disclosing this way should be the exception, though, not the rule.

Where can I find a list of the IRPs?

Here.

How can I find out what companies an IRP is promoting?

Go to the User's profile and click on the golden triangle, then click on View My Disclosures/Disclaimers.

It says right in this guy's disclaimer that he's been paid to promote the company I'm in. But he never has the disclaimer in his posts!

That may be an oversight on his part, so you might mention that to him via PM if you are a Premium Member. If you do not have PM privileges, you can ask an Admin to relay the message for you.

In any event, any legal requirement to disclose is a matter for duly empowered regulatory agencies; iHub does not enforce those requirements. If you believe there is a material failure to disclose here or anywhere else, then you have the option of contacting the appropriate agency.

This guy is an IRP. I asked if he was promoting the company I'm in and it was deleted?!?!?!

Many IRPs also post on boards they have not been compensated to promote. On stock-specific boards, their IRP status and promotional activities are off-topic unless there is public domain disclosure that they have been compensated to promote the stock in question.

This one woman has in her disclaimer that she was paid by a third party. I've asked on the board twice now who the third party is and she just ignores my question. Legally, she HAS to tell me.

Users can certainly ask that question of IRPs. However if the individual chooses not to answer, then continuing to post the same message requesting this is considered spam, disruptive, and possibly harassment.

While you may be correct that IRPs are legally mandated to disclose this information, that is not something we have the authority to dictate. Enforcement of this would need to be discussed with the regulatory agency responsible for mandating such disclosures.

I know this lady is an IRP, but she hasn't signed up for the program. What do I do?

If it's conjecture on your part, then please keep it to yourself. If you have hard facts, then please send links documenting the connections to Shelly. Do not post about it on the boards.

I don't understand why people are allowed to post that my promotion company has a bad rep on the stock board I moderate. This is MY company and I consider it a personal attack not to mention that my client monitors the board.

Discussing a promotion company's reputation and/or successfulness is and has always been on topic on the stock boards. Opinions about a company cannot be a personal attack. As long as the messages are focused on the promotion of the specific stock, then that is considered valid, on topic dialog.

This one guy addresses me as "Pumper" every time he replies to me. I'm always respectful to him but this is really getting on my nerves.

Calling other User's names (pumper, tout, basher, naysayer, etc.) is considered either off topic or a personal attack and these messages should be removed. Please hit the Report TOS button to report these instances.

I'm sick of being called a POS scumbag on the boards! I don't think that just because I'm disclosing that I am compensated for awareness that I deserve to be talked to like that!

Agree, this would be considered a personal attack and should be removed. Please hit the Report TOS button to report messages like this.

I always forget to click that box. Can I just put my disclaimer in my signature and be done with it?

IRPs are permitted to place a link to their iHub Disclaimer page in their signature and/or profile only while they have an active IRP subscription. There should be no disclaimers or links to disclaimers of compensation in signatures, profiles or posts (at the time of posting) by any one who is not an active IRP. IRPs that allow their status to go inactive must immediately remove disclaimers and links to their disclaimer from their current signature and profile.

Individual IRP disclaimer pages will always be visible once an IRP account has been activated. The disclaimer icon optionally included inside of IRP posts are also permanent. Disclaimers in signatures and profiles are not and should not be considered permanent. Those references can and may be removed/hidden at any time by site Admins and should not be relied upon as a means to make legally required disclaimers.

This one trading board always focuses on the companies I'm promoting and is continually posting a "scorecard" about my activities. I'm not paid to raise the stock price, I'm compensated to create awareness of the company. I think this is unfair and should not be allowed.

Discussing a promotion company's reputation is and has always been on topic on the general stock discussion boards. Many Users associate a successful promotion with an increase in the share price and this is considered valid for general trading boards.

I did one promotion 6 months ago for one week of a stock. The pps is in the toilet now and this one guy constantly refers back to the time I was promoting!

As long as the messages are about a business relationship between your company and the specific stock, then it doesn't violate the rules here. Historical references to past business decisions the company has made have always been considered valid discussion. You still have the same recourse as other Users, either ignore it or debate it civilly within the rules of the site.