Retail Customer Disclosures - SEC Regulation Best Interest Disclosures (Reg BI)

On June 5, 2019, the SEC adopted Regulation Best Interest (Reg BI) under the Securities Exchange Act of 1934. Reg BI establishes a “best interest” standard of conduct for broker-dealers and associated persons when they make a recommendation to a retail customer of any securities transaction or investment strategy involving securities. Reg BI is effective as of June 30th, 2020. Odeon is happy to provide it's retail customers with the following information as required under Reg BI.

Please view Odeon's Customer Relationshp Summary (Form CRS) HERE.

Please view Odeon's Customer Disclosure Brochure HERE.

*Additional disclosures for retail and custodial accounts: please reference our Clearing Firm's Disclosure Package HERE.

Please view our Privacy Statement HERE.

Analyst Certifications

Odeon Capital Group requires Research Analysts to certify the views expressed in research reports accurately reflect their personal views about subject companies and their securities. They also certify that they have not, will not, nor are they presently receiving direct and/or indirect compensation in exchange for any specific recommendation in a report. In addition, analysts will certify that they have not received compensation from any subject company in the last 12 months.

Rating Definitions

*Definitions of Ratings Revised as of May 7th, 2013.

Financial Interests

An equity analyst or a member of its household may not purchase the securities of a subject company 30 days before or 5 days after the issuance of the research analyst’s report or a change in ratings or price targets, trade inconsistent with the views expressed by the research analyst, and all transactions in a research analyst's personal trading account must be pre-approved. Neither the research analyst nor any member of his/her household may own any of the securities of the subject company including any options, rights, warrants, futures or long or short positions. An equity analyst may not trade contrary to his/her own recommendation in a research report. Neither a research analyst nor any member of his/her household may own 1% or more of any of the securities of the subject company based upon the same standards used to compute beneficial ownership for the purpose of reporting requirements under Section 13(d) of the Securities Act of 1934, as amended. Neither a research analyst or household member may be an officer, director, or advisory board member of the subject company. A research analyst may not make a public appearance in front of more than 15 persons to discuss the subject company and may not know or have reason to know at the time of this publication of any other material conflict of interest.

Receipt of Compensation

Receipt of Compensation: The research analysts at the firm do not receive any compensation based on investment banking revenues and may be paid a bonus based upon the overall profitability of the firm.

Technical Analysis

This research report contains technical analysis which only takes into account historical price performance and it is not an analysis of fundamental factors or other price/risk indicators. When making an investment decision technical analysis alone should not be the only factor to take into consideration. Any price target or recommendation contained in this report based soley on technical analysis is valid as of the date of this publication only and the analyst’s “coverage” of the securities referenced begins and ends the same day. The research analyst welcomes and encourages any comments or questions with regard to this research report.

Fixed-Income Research

Our research products are intended for institutional investors and are not subject to all of the independence and disclosure standards applicable to research reports prepared for retail investors. If you do not contact us and request to be removed from our research distributions, we will reasonably conclude that you have consented to receiving institutional research products, and that you are a Qualified Institutional Buyer (QIB) or acting on behalf of a QIB.

Other Additional Disclosures

The firm does not make markets in any securities whatsoever. The firm buys or sells securities for its own account. The firm buys or sells securities on a principal basis with customers. The firm’s employees who are not equity research analysts may buy or sell securities. Although the statements of fact in this report have been obtained from and are based upon outside sources that the firm believes to be reliable, the firm does not guarantee the accuracy or completeness of material contained in this report. Any such estimates or forecasts contained in this report may not be met. Past performance is not an indication of future results. Calculations of price targets are based on a combination of one or more methodologies generally accepted among financial analysts, including but not limited to, analysis of multiples and/or discounted cash flows (whether whole or in part), or any other method which may be applied. Rating, target price and price history information on the subject company (ies) in this report is available upon request. To receive any additional information upon which this report is based this information please contact 212-257-6970, or write to Research Production Department, Odeon Capital Group LLC, 750 Lexington Avenue, 27th fl. New York, New York 10022.

Odeon Capital Group LLC is a U.S. registered broker-dealer and member of FINRA, SIPC and MSRB. This report is prepared for general circulation. The information herein does not constitute a solicitation of an offer to buy or an offer to sell any security nor is it intended to be a complete summary or statement of all available data. This report is not produced based on any individual persons or entities investment objectives or financial situation and opinions expressed by the analyst are subject to change without notice. This report is not provided to any particular individual with a view toward their individual circumstances. Investors should consider this report as only a single factor in making an investment decision. As with any transaction having tax implications, investors should consult with their tax advisor before making investment decisions designed to generate tax benefits. As a matter of policy the firm does not offer tax advice and nothing herein should be construed as offering such advice. The securities mentioned in this report are highly speculative and involve a high degree of risk. Securities prices fluctuate and investors may receive back less than originally invested and are not guaranteed. International securities involve additional risks such as currency fluctuations, differing financial accounting standards, and possible political and economic instability. Small-cap stocks generally involve greater risks. Dividends are not guaranteed and will fluctuate. The securities recommended, offered, or sold by the firm, are not insured by the Federal Deposit Insurance Corporation, are not deposits or other obligations of any insured depository institution, and are subject to risks, including the possible loss of principal amount invested. Any opinions, estimates or projections expressed in this report may assume some economic industry and political considerations and constitute current opinions, at the time of issuance, and are subject to change. No part of this document may be copied, photocopied, or duplicated in any form or other means redistributed or quoted without the prior written consent of the firm. This report and its contents are the property Odeon Capital Group LLC and are protected by applicable copyright, trade secret or other intellectual property laws (of the United States and other countries). United States law, 17 U.S.C. Sec.501 et seq, provides for civil and criminal penalties for copyright infringement.

Disclosures to Customers

Please view our Customer Disclosure Brochure HERE.

Business Continuity Plan

Please view our Business Continuity Plan Notice HERE.

SEC Rule 605 requires certain FINRA member firms to report to FINRA certain order execution information for listed equity securities. Odeon Capital Group generally reports fewer than 200 transactions per trading day in listed equity securities. Accordingly, the firm is not required to report pursuant to Rule 605. If and when the Firm is required to provide Rule 605 reports, such reports will be posted at www.odeoncap.com/legal.

In Accordance with SEC Rule 606 Odeon Capital Group is providing its customers with this annual notice regarding a customer’s right to information concerning the routing of their orders for execution.

Odeon Capital Group is required to publish quarterly statistics regarding its customer agency order routing practices. The purpose of the report is to provide the public with information on how broker-dealers route their customers’ orders, to enable customers (and others) to evaluate order routing practices. The Rule was adopted by the SEC to enhance market transparency and foster competition among market participants. This information is available on the internet at the following link and in hard copy for those who do not have access to the internet. The report is published by the end of the month following the calendar quarter reported.

In accordance with U.S. Securities and Exchange Commission (SEC) Rule 606, Odeon Capital Group is publishing statistical information about our routing practices for Held non-directed orders in NMS equity securities and options.

U.S. Securities and Exchange Commission (SEC) Rule 606(a) requires all brokerage firms to make publicly available quarterly reports, broken down by calendar month, containing certain required statistical information regarding the routing of held, non-directed customer orders in Regulation NMS stocks and listed options.

The report contains a section for Regulation NMS stocks (separated by securities that are included in the S&P 500 Index as of the first day of the quarter and other Non-S&P 500 stocks) and a separate section for listed options. For each section, the report identifies the venues to which NS routed the relevant orders and, for each venue, the required statistical information broken down by order type (i.e., market order, marketable limit order, non-marketable limit order and other orders). Each section of the report also contains information regarding the material aspects of NS’s relationship, if any, with each venue. Odeon Capital Group is publishing such quarterly report in accordance with Rule 606(a), and will keep the report publicly available for a period of three (3) years.

Odeon's Rule 606 Reports

2024 Q3 - PDF:XML
2024 Q2 - PDF:XML
2024 Q1 - PDF:XML
2023 Q4 - PDF:XML
2023 Q3 - PDF:XML
2023 Q2 - PDF:XML
2023 Q1 - PDF:XML
2022 Q4 - PDF:XML
2022 Q3 - PDF:XML
2022 Q2 - PDF:XML
2022 Q1 - PDF:XML
2021 Q4 - PDF:XML
2021 Q3 - PDF:XML
2021 Q2 - PDF:XML
2021 Q1 - PDF:XML
2020 Q4 - PDF:XML
2020 Q3 - PDF:XML
2020 Q2 - PDF:XML
2020 Q1 - PDF:XML

YOU SHOULD READ THIS LEGAL AND PRIVACY STATEMENT BEFORE USING THIS WEBSITE.

By continuing to access or use this website, you expressly acknowledge and agree to the terms and conditions set forth in this Legal and Privacy Statement. Odeon reserves the right to modify this Legal and Privacy Statement at any time, so you should review these terms and conditions whenever accessing or using this website. By using the website after the posting of modifications to the terms and conditions set forth in this Legal and Privacy Statement, you signify your acceptance of such terms and conditions, as modified. You may not use this website if, at any time, you do not wish to accept the terms and conditions as set forth in this Legal and Privacy Statement.

All information and material including images, text and audio on this website is the property of Odeon Capital Group LLC (“Odeon”) and is subject to copyright. All other trade marks, if any, on this website are the property of their respective owners. You are entitled to view, copy and print any documents from this website but only for your own internal business purposes. You acquire absolutely no rights or licenses in or to the website or the materials contained within the website other than the limited right to use the website in accordance with this Legal and Privacy Statement. Any sale, transmission or redistribution of this website or its content, and any copying, modification or other use of this website or its content for any purposes other than your own internal business purposes, are strictly prohibited. All present and future rights in and to trade secrets, trademarks, service marks, copyrights and other proprietary rights under the laws of any domestic or foreign governmental authority (the “Intellectual Property Rights”) shall at all times be and remain the sole and exclusive property of Odeon as between you and Odeon. Except as specifically permitted by the terms of this Legal and Privacy Statement, you shall not use the Intellectual Property Rights or the website, or any derivations thereof, for any purpose, without Odeon’s prior written approval. You agree to protect the proprietary rights of Odeon and all others having rights in the website and to comply with all reasonable written or electronic requests made by Odeon or its suppliers of content or otherwise (“Suppliers”) to protect their and others’ contractual, statutory and common law rights in the website. You agree to provide Odeon with prompt written notice of any unauthorized access or use of the website by any party or of any claim that the website infringes upon any copyright, trademark or other contractual, statutory or common law rights.

This website is provided solely for information purposes and, with the exception of this Legal and Privacy Statement or as otherwise indicated, is not intended to, and shall not, constitute any offer or acceptance with the respect to any transactions or other matters. Except for this Legal and Privacy Statement, this website shall not create any legal relationship between you and Odeon.

This website and the information and material which it contains are subject to change at any time by Odeon without notice and Odeon reserves the right to suspend, terminate or restrict your access to or use of this website. This website is provided “AS IS” without any warranty of any kind, express or implied, including, but not limited to, any implied warranty of merchantability, fitness for a particular purpose, accuracy or completeness of the information contained on this website or in respect of any materials or products referred to on this website, or non-infringement. Difficulties in use of this website could involve, among others, failures, delays, malfunction, software erosion, inadvertent disclosure of information provided to Odeon via this website, or hardware damage, which difficulties could be the result of hardware, software or communication link inadequacies or other causes. Such difficulties could lead to possible economic and/or data loss. Odeon does not warrant that the website is compatible with your equipment or that the website is free of errors, viruses or worms. In no event shall Odeon be liable for any damage you may suffer as a result of such destructive features. All warranties, whether express or implied, are hereby excluded to the extent permitted by law.

Odeon and its directors, officers, employees and agents shall, to the extent permitted by law, have no liability, contingent or otherwise, whether caused by the negligence of Odeon, its employees, subcontractors, agents, Suppliers, or otherwise, to you or to third parties for the accuracy, timeliness, completeness, reliability, performance or continued availability of this website or for delays or omissions therein, including, but not limited to, inaccuracies or errors in or omissions from quotes and financial data. Odeon shall have no responsibility to maintain the information or services made available on this website or to supply any corrections or updates in connection with such information or services. IN NO EVENT WILL ODEON, ITS SUPPLIERS, OR ITS THIRD PARTY AGENTS BE LIABLE TO YOU FOR ANY DIRECT, SPECIAL, INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING, WITHOUT LIMITATION, LOSS OF BUSINESS, LOSS OF PROFIT, LOSS OR CORRUPTION OF DATA, LOSS OF GOODWILL OR REPUTATION OR WASTED MANAGEMENT TIME) WHICH MAY BE INCURRED OR EXPERIENCED ON ACCOUNT OF YOUR USING OR RELYING ON THIS WEBSITE OR ANY INFORMATION OR LINKS ON IT , EVEN IF ODEON HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. Any limitations or restrictions on liability in this Legal and Privacy Statement shall only apply to the extent permitted by applicable law. In no event shall Odeon’s total liability to you for all damages, losses and causes of action (whether in contract or tort, including but not limited to, negligence) exceed the amount paid by you to Odeon, if any, for accessing this website.

Nothing set forth in this website should be construed as a recommendation to purchase or sell any product or instrument or to enter into any transaction, or as a representation that any particular product or instrument is suitable or appropriate for you. Many of the products described in this website involve significant risks and you should not enter into any transactions unless you fully understand all of these risks and have independently determined that the risks are acceptable to you and that the transactions are appropriate for you in light of your objectives, experience, financial and operational resources and other relevant circumstances. Any discussion of risks contained in this website, however, should not be considered to be a disclosure of the risks of particular transactions, or a complete discussion of the risks which are mentioned.

You should not construe any of the material contained in this website as business, financial, investment, hedging, trading, legal, regulatory, tax or accounting advice and you should not make this website the primary basis for any trading decisions. In providing this website and entering into any transactions in the products described in this website, Odeon is acting solely in the capacity of an arm’s length contractual counterparty and not as a financial advisor or a fiduciary. Under no circumstances should Odeon be considered your advisor or fiduciary and, if you require advice with respect to the products identified in this website or any contemplated transactions, you should consult your own business, financial, accounting or legal advisors.

This website may provide links to certain websites sponsored and maintained by Odeon as well as those sponsored or maintained by third parties. Such third party websites are publicly available and Odeon is providing access to such websites through this website solely as a convenience to you. The content of such third party websites, services, goods or advertisements that may be linked to this website is not maintained or controlled by Odeon, and Odeon makes no representations or warranties concerning the content of such websites and the fact that access to such websites is provided does not constitute any endorsement, authorization or sponsorship of such websites or their sponsors by Odeon nor is there any affiliation between Odeon and such sponsors and such sponsors do not endorse, authorize or sponsor this website. Moreover, Odeon is in no way responsible for the availability, content or accuracy of other websites, services or goods that may be linked to, or advertised on, the website and does not make any warranty, express or implied, with respect to the use of the links provided on, or to, the website or guarantee the accuracy, completeness, usefulness or adequacy of any other websites, services, goods or advertisements that may be linked to the website. You understand and agree that you will use or rely on such websites solely at your own risk and that Odeon does not grant to you any rights in respect of such websites.
In the course of your use of this website, you may provide, or Odeon may otherwise obtain, information about you or your business activities. By using this website, you expressly consent to Odeon (1) using this information to assess the function and performance of this website, to assess the needs of its customers, to market Odeon’s products and services and for the other purposes set out in this paragraph, and (2) transferring this data to Odeon affiliates throughout the world for the purposes specified in (1) above. Any information which you provide or which Odeon otherwise obtains will be used by Odeon for any and all business purposes. In the event that Information is submitted through your access to the website erroneously, or you later determine that Information should not have been submitted, for any reason, You accept full financial responsibility for such entry. Further, by logging onto to our website on behalf of an entity or corporation, you are agreeing that you have the right and authority to bind that entity or corporation to the obligations and responsibilities incurred by utilizing this website.

You agree, at your own expense, to indemnify, defend and hold harmless Odeon and its employees, representatives, Suppliers and agents, against any claim, suit, action or other proceeding against Odeon, its employees, representatives, Suppliers and agents, by a third party, to the extent that such claim, suit, action or other proceeding is based on or arises in connection with your use of the website, or any links on the website, including, but not limited to: (i) your use or someone using your computer’s use of the website; (ii) your use or someone using any password you may obtain; (iii) a violation of the terms set forth in this Legal and Privacy Statement by you or anyone using your computer or password; (iv) a claim that any use of the website by you or someone using your computer or password infringes any intellectual property right of any third party, is libelous or defamatory, or otherwise results in injury or damage to any third party; (v) any deletions, additions, insertions or alterations to, or any unauthorized use of, the website by you or someone using your computer or password; (vi) any misrepresentation or breach of representation or warranty made by you contained herein: or (vii) any breach of any covenant or agreement to be performed by you hereunder. You agree to pay any and all costs, damages and expenses, including, but not limited to, reasonable attorneys’ fees and costs awarded against or otherwise incurred by or in connection with or arising from any such claim, suit, and action or proceeding attributable to any such claim.

The terms of this Legal and Privacy Statement shall be governed by, and construed in accordance with, the laws of the State of New York applicable to contracts made and to be fully performed in such State without reference to principles of conflict of laws. The user of this website agrees that by using this web they submit to the jurisdiction of the Supreme Court of the State of New York and the United States District Court for the Southern District of New York for the enforcement of the terms of this Legal and Privacy Statement and any disputes related to same and agrees to service of process by mail.

Important Legal Information

Odeon and its affiliates do not intend the information provided on this site to be distributed to, or used by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Odeon or its affiliates to any registration requirement within such jurisdiction or country. Neither the information, nor any opinion contained in this site constitutes a solicitation or offer by Odeon or its affiliates to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service.

Although the information provided to you on this site is obtained or compiled from sources we believe to be reliable, Odeon cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. Neither Odeon, nor any of its affiliates, directors, officers or employees, nor any third party vendor will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this site, or resulting from the act or omission of any other party involved in making this site or the data contained therein available to you, or from any other cause relating to your access to, inability to access, or use of the site or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Odeon or of any vendor providing software or services support.

Current and future holdings are subject to risk and past performance is no guarantee of future results. Podcasts should not be copied, distributed, published, or reproduced, in whole or in part. Information presented herein is for discussion and illustrative purposes only and is not a recommendation or an offer or solicitation to buy or sell any securities. Securities identified do not represent all of the securities purchased, sold, or recommended to clients. The views and opinions expressed by the Odeon Capital Group speaker are their own as of the date of the recording. Any such views are subject to change at any time based upon market or other conditions and Odeon Capital Group disclaims any responsibility to update such views. These views should not be relied on as investment advice, and because investment decisions are based on numerous factors, may not be relied on as an indication of trading intent on behalf of any Odeon Capital Group product. Neither Odeon Capital Group nor the speaker can be held responsible for any direct or incidental loss incurred by applying any of the information offered.