Advertising and securities disclosures

Last updated 12 August 2026.

This page sets out the compensation disclosures Richport Media Inc. makes for the articles it is paid to publish, the law they are made under, and where its publication does not yet meet them.

Richport Media Inc. is a marketing firm. Issuers pay us, in cash, to write and publish articles about their companies and to direct their marketing budget to the placements that bring investors to those articles. United States securities law requires that payment to be disclosed in the article itself.

Compensation and status. The issuer profiled in an article is the party that pays for it. The payment is cash: no shares, no options, no warrants, no success fee, and no fee determined by price or trading volume. Richport Media Inc. holds no position in any client security — before, during or after an engagement. We are not a broker-dealer and not an investment adviser. Nothing we publish is investment advice, research, or a recommendation, and nothing on this site or in any article is an offer to sell or a solicitation of an offer to buy any security.
No paid article has been published. Richport Media Inc. has not published a paid article under its own name. Our publication is live and carries unpaid, AI-drafted coverage. The label set out below is a standard adopted ahead of the first paid article, not a description of articles published today. The shortfalls in the current template are listed in the gap.

What Richport does

  • Who pays.The issuer profiled in the article, under a written engagement with Richport Media Inc. Where a campaign is funded by anyone other than the company — an officer, director, affiliate, shareholder or intermediary — that payer is named in the label, by legal name, alongside the issuer.
  • What form the payment takes.Cash. One flat engagement fee for the promotional window, plus an advertising budget that passes through at cost. No securities of any kind, in any amount, at any point in a Richport Media Inc. engagement.
  • What the money buys.We write the article, publish it on Global Securities News, and direct the issuer’s marketing budget to the placements that bring readers to it. Targeting and media mix are proprietary and are not disclosed; the money and the market are reported to the client in full. See the method.
  • Whose side we are on.The issuer’s: Richport Media Inc. is its paid advocate, and every paid article we publish was commissioned and paid for by the company it describes.
  • What we are not.Not a public relations firm and not an investor relations firm. No press releases, no disclosure work, no shareholder-facing IR, no roadshows, no analyst introductions, no pitching journalists. The full list is on the limitations page.
Lineage. The campaigns documented on this site were delivered by Vincent under contract to the third-party firms of record named in each case. Those firms — not Richport Media Inc. — were the issuers’ vendors of record, and the published content and its required disclosures belonged to them and to the issuers. Some of those engagements involved share-based vendor compensation paid to the firm of record, which is why the footer on every page of this site excludes it from the multiplier denominator. The cash-only rule above applies to Richport Media Inc.’s own engagements. It is not a claim about that history, which is set out in the case studies.

Where articles are published

  • The publication has a name.Global Securities News. Richport Media Inc. holds editorial responsibility for everything published there, and the publication states that in its AI Content Disclosure.
  • The articles are drafted by AI.Every article is drafted by an AI system from primary sources: filings, exchange disclosures and company releases. Each carries a visible label beside the byline, and the publication’s AI Content Disclosure sets out the pipeline in fulfilment of Article 50 of Regulation (EU) 2024/1689.
  • The byline is a desk, not a person.Articles run under “GSN AI Editorial Team” or “GSN AI Newsdesk.” No article runs under an invented human persona, and no byline carries a fabricated biography, track record or credentials.
  • Human review is limited.The pipeline runs on automated checks, not line-by-line human review. No claim is made that each article was individually fact-checked by a human before it ran.
  • Paid articles carry the paid label.A paid article is one an issuer commissioned and paid for, and it carries the paid label. If an article has no paid label, no issuer bought it.
Confidentiality terms. Richport Media Inc. does not sign a confidentiality term that would prevent it disclosing what it was paid for an article.

Securities Act Section 17(b)

Section 17(b) of the Securities Act of 1933, codified at 15 U.S.C. 77q(b), is the anti-touting provision.

The operative words. It is unlawful “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.”
  • The duty is ours.The statute binds “any person” who publishes, gives publicity to, or circulates the communication; it is not the issuer’s duty discharged on our behalf. Richport Media Inc. writes, publishes and circulates the article, and owes the disclosure on each one.
  • Describing is enough to trigger it.The communication only has to “describe” a security. No recommendation, rating, price target or offer is required: the statute reaches communications “though not purporting to offer a security for sale.” An investor-awareness article about an issuer’s stock is inside the trigger.
  • What must be disclosed.The statute names the receipt of consideration, whether it is past or prospective, and the amount. The SEC’s stated position adds the nature and the source of the compensation. Richport Media Inc. discloses all of them.
  • No intent is required.In SEC v. Lidingo Holdings, LLC (No. 1:17-cv-02540, S.D.N.Y., filed 10 April 2017) the failure-to-disclose count recites the statutory language word for word and alleges no state of mind, separately from the fraud counts. A labeling shortfall with no fraudulent intent is still a violation.
  • There is no minimum.The statute says “a consideration.” No de minimis floor, no carve-out by form of payment, and no element requiring the promoter to hold or trade the security.
  • The First Amendment is not a defence.The SEC obtained relief under § 17(b) over a press-freedom defence, for feature articles sponsored by the companies they profiled, in SEC v. Wall Street Publishing Institute, Inc., 851 F.2d 365 (D.C. Cir. 1988), cert. denied, 489 U.S. 1066 (1989). Richport Media Inc. does not argue that publishing an article makes it something other than an advertisement.
A partial label is still a violation. Kim Kardashian labeled her EthereumMax post “#AD.” The SEC charged and settled a § 17(b) violation anyway, because she did not disclose that she had been paid by EthereumMax, or the amount (In re Kim Kardashian, Securities Act Release No. 33-11116, 3 October 2022; $1.26 million in total, comprising $250,000 disgorgement, prejudgment interest and a civil penalty). Her consideration was a flat cash fee and she held no position. She still owed the full disclosure. An advertising label that satisfies the FTC does not satisfy § 17(b).
The enforcement pattern. On 10 April 2017 the SEC charged 27 individuals and entities over paid stock articles, with settlements running from roughly $2,200 to nearly $3 million (SEC Press Release 2017-79). More than 250 of the articles affirmatively stated that the writer had not been compensated.

Section 17 is enforced by the Commission; courts have not implied a private right of action under it. A paid article that is materially misleading is actionable under § 10(b) and Rule 10b-5 regardless of how it is labeled.

The disclosure label

This page does not carry the disclosure. The disclosure that satisfies the law sits on the article, above the headline. A page on a different site, reached by a different click, does not cure a missing or incomplete label.

Eight elements, in one block, on the article.

  • The words “Paid Advertisement.”One string, used everywhere we publish. Not “Promoted,” not “Sponsored by,” not “Presented by”; see the FTC section. The publication does not render this string yet; see the gap.
  • That we were paid to produce and publish it.Named: Richport Media Inc. was compensated to write and publish the article. Not that someone was compensated, and not that the article “may” be paid.
  • Who paid, by legal name.The issuer, any intermediary through which the payment was routed, and any officer, director, affiliate or shareholder who funded it instead of the company.
  • The amount, in figures and currency.With the period and campaign it covers, and an express statement that the figure is campaign-level rather than allocated per article. See the amount.
  • Whether the consideration is past or prospective.The statute requires this distinction in terms. An article published mid-campaign, against a fee not yet fully paid, says so.
  • The form: cash only.No shares, options, warrants or other securities; no success fee; no compensation determined in whole or in part by price or trading volume.
  • Our position: none.Richport Media Inc. holds no position, long or short, direct or indirect, in the securities of any client — before, during or after an engagement.
  • Whose behalf the record is issued on.For Canadian-facing articles, a clear and conspicuous statement that the record is issued by or on behalf of the named issuer. This is a separate requirement from compensation disclosure; see Canada.

Where the label appears:

  • Above the headline, on the article.In front of or above the headline, above the fold, in type that contrasts with the background, with a visual separator.
  • On every index card that surfaces the headline.A label on the listing page does not cover a direct link, and a label on the article does not cover a reader who only sees the card.
  • In the title tag and the social title.The label string leads the page title and the Open Graph title, so that it survives search results, social shares and email forwards.
  • Never behind a click.A disclosure met only after clicking through does not cure the impression created before the click, and a disclosure buried in body text does not fix a headline (FTC, Enforcement Policy Statement on Deceptively Formatted Advertisements, 22 December 2015).

Current template gaps

The publication does not yet produce the standard set out above.

  • The label string is wrong.The article template renders a “Sponsored Content” badge, which is not among the terms the FTC lists as understood by readers. It becomes “Paid Advertisement.”
  • It sits below the headline.The notice renders after the article header, at the top of the body. The FTC instruction is in front of or above the headline. It moves above the headline.
  • The amount is not in it.The rendered notice names the sponsor and says the article is paid content. It states no amount, no period, no past-or-prospective distinction, no cash-only statement and no position statement. That is the shortfall charged in Kardashian.
  • The label does not travel.The page title and the Open Graph title carry the headline alone. A search listing or a social share of a paid article would today carry no disclosure at all.
  • Three strings, one publication.Display advertising is labeled “Advertisement” and third-party recommendation links are labeled “Promoted Content,” a term the FTC calls at best ambiguous. Three strings is not consistent terminology.
  • The notice describes someone else’s model.The template’s wording says the article was produced in partnership with the sponsor and was not written by editorial staff. Richport Media Inc. writes the article, and the notice has to say so.
Status of these items. No paid article has run under the current template. Each item above is a change to be made before one runs, not a defect in a published article.

How compensation is stated

Section 17(b) was drafted for a discrete paid article. Our model is a flat fee covering a promotional window, several pieces of content, and a media budget we direct to third parties. No SEC rule, no-action letter or court decision says how to divide a retainer across the articles it produced.

  • The total consideration.The full amount Richport Media Inc. received or is to receive for the campaign, in figures and in the currency paid.
  • The period it covers.Start and end of the promotional window the fee relates to.
  • What the fee produced.The number of pieces of content published under the campaign.
  • The media budget we directed.Stated separately from our fee. It is the issuer’s money passing through at cost to third-party placements: not income to Richport Media Inc., but consideration from the issuer.
  • That the figure is campaign-level.Stated in the label, so that a campaign total is not mistaken for the price of a single article.
No allocation method is regulator-approved. The Commission has accepted aggregate campaign figures in pleadings and settled orders — the Lidingo and Galena papers recite them, including at least $460,000 in monthly fees plus a $20,000 bonus paid by Galena Biopharma to the promotion firm — but has never approved an allocation method. We disclose the aggregate, label it as the aggregate, and put it in the on-page label rather than behind a link. If a regulator or a court specifies a method, Richport Media Inc. will use it.

Handling of campaign funds

The statute reaches consideration received “directly or indirectly, from an issuer, underwriter, or dealer.” A payment routed from the issuer to us and on to a writer or a placement is still consideration from the issuer.

  • Each placement owes its own disclosure.Every downstream publisher, writer or channel that describes the security for consideration we passed along carries its own § 17(b) duty, which our label does not discharge.
  • We are exposed if they fail.Aiding and abetting a § 17(b) violation is a charge the Commission brings; it did so in Lidingo. Richport Media Inc. does not buy a placement that will not carry the label.
  • We do not use the source-clause argument.We do not accept third-party-funded campaigns on the basis that a payer who is not an issuer, underwriter or dealer falls outside § 17(b). We name the payer and state the amount either way.
  • We name insiders and affiliates as payers.The SEC’s investor alert on fraudulent stock promotions warns that a disclosure can be used to manufacture legitimacy while concealing that the real source of the money is a company insider or affiliate. We name the source.

Compensation and positions

The compensation structure addresses fraud and manipulation exposure. It does not reduce the disclosure duty under § 17(b).

  • What it defuses.Holding a position while promoting a security — scalping — is the fraud theory under § 10(b) and § 17(a) (SEC v. Capital Gains Research Bureau, Inc., 375 U.S. 180 (1963)), and a promoter fee that rises with the share price has been treated as evidence of manipulation. We have neither: no position at any time, and no compensation determined in whole or in part by price or volume.
  • What it does not touch.Section 17(b). Cash is not an exemption; there is no form-of-payment carve-out and no requirement that the promoter hold the security. Kardashian was cash-only, position-free and performance-unlinked, and still owed the full disclosure.
  • Cash is also the exchanges’ rule.The Canadian Securities Exchange states that share compensation for promotional work is not acceptable, that payment should be on a cash basis, and bars compensation determined in whole or in part by an issuer’s securities reaching price or volume thresholds. TSX Venture Policy 4.4 prohibits issuing securities for investor relations, promotional or market-making services. The SEC treats anyone whose services promote or maintain a market for the registrant’s securities as a statutory underwriter, closing the Form S-8 route. See the limitations page.

Not a broker-dealer or adviser

What Richport Media Inc. publishes is advertising. It is not research and it is not investment advice.

  • Not a broker or a dealer.Not registered as a broker-dealer with the SEC, not a member of FINRA, not registered in any Canadian jurisdiction. We do not solicit anyone to buy or sell a security, participate in financings, handle investor funds or securities, or take a success fee or percentage of a raise.
  • Not an investment adviser.Not registered as an investment adviser in any jurisdiction, and we do not act as one. We publish no ratings, price targets, valuations, financial models, buy or sell opinions, or recommendations of any kind, general or personalised, and nothing we publish is tailored to any reader’s circumstances.
  • The publisher exclusion we do not claim.The Investment Advisers Act excludes “the publisher of any bona fide newspaper, news magazine or business or financial publication of general and regular circulation” (15 U.S.C. 80b-2(a)(11)(D)), read broadly in Lowe v. SEC, 472 U.S. 181 (1985). Richport Media Inc. does not rely on that exclusion; it stays outside the Advisers Act by publishing no advice.
  • No offer, no relationship.Nothing on this site or in any article we publish is an offer to sell, or a solicitation of an offer to buy, any security in any jurisdiction. Reading an article creates no advisory, fiduciary, brokerage or client relationship.
  • Disclosure is not the whole regime.Promoters may also be liable under the anti-fraud provisions, for participating in an unregistered offer and sale of securities, and for acting as unregistered brokers. In In re Galena Biopharma, Inc., Securities Act Release No. 33-10337, the company and its former chief executive consented to cease-and-desist orders covering Securities Act §§ 5(a), 5(b), 5(c), 17(a) and 17(b).
Primary sources. Our articles are restricted to already-public information, so that every claim can be checked against the primary document. No article is a substitute for the issuer’s own filings.

Forward-looking statements

Articles are built from public filings and news releases and restricted to information the company has already published, including its own disclosed risks.

  • Whose statement it is.Where an article carries a forward-looking statement — plans, targets, timelines, production or resource estimates, projected results — it is the issuer’s statement, attributed to the issuer’s own filing or release. We do not adopt it, endorse it, or represent that it will be achieved.
  • We make none of our own.We publish no projections, forecasts or estimates about any issuer’s business, financial results, share price or trading volume.
  • The source governs, not our summary.The issuer’s cautionary language, assumptions and risk factors are in the filing the statement came from. We do not evaluate them.
  • We claim no statutory safe harbour.The federal safe harbour is the issuer’s to invoke, and by its own terms does not apply to a statement made with respect to the business or operations of an issuer that issues penny stock (15 U.S.C. 78u-5(b)(1)(C); the parallel Securities Act provision is 15 U.S.C. 77z-2). Many small-cap issuers issue penny stock.

No market outcome is guaranteed, and no fee we charge is tied to one. The campaign-outcome and attribution disclaimers sit in the footer of every page.

FTC endorsement and native advertising rules

Section 5 of the FTC Act (15 U.S.C. 45(a)(1)) makes deceptive acts and practices unlawful. Advertising not identifiable as advertising is deceptive if it misleads people into believing it is independent or impartial.

  • The terms the FTC accepts.The FTC’s Native Advertising: A Guide for Businesses lists “Ad,” “Advertisement,” “Paid Advertisement” and “Sponsored Advertising Content” as terms consumers understand, and says “Promoted” is at best ambiguous. It notes that “Sponsored by [X]” and “Presented by [X]” may be read to mean the advertiser funded but did not create the content; Richport Media Inc. writes the content.
  • One term, everywhere.Consistent terminology is an express FTC expectation: the same string on the article, the index card, the title tag and the share card. The publication does not meet that standard today; see the gap.
  • Prominence is measurable, not decorative.Clear and unambiguous language, a font and colour that are easy to read, a shade that stands out against the background, and a border or separator so the block does not rely on colour alone. A logo or company name by itself is not a signal that content is advertising.
  • Format has to differentiate too.The FTC has warned since 1967 that a format which exactly duplicates a news or feature article can render the caption “ADVERTISEMENT” meaningless. A label alone is not always sufficient.
  • The disclosure travels with the article.Advertisers are required to maintain disclosures when native advertising is republished in search results, social media and email. The label leads the title tag and the social title, not the page body alone.
  • Everyone in the chain is exposed.The Endorsement Guides put duties on the advertiser for failing to disclose unexpected material connections and for failing to guide and monitor, and on the endorser for representations it knows or should know to be deceptive (16 CFR 255.1(d)–(e)). The native advertising policy reaches anyone who helps create or present the ad, including agencies. We create the content and place the budget, so both apply to us.
Where the two regimes diverge, the securities rule governs. 16 CFR 255.5(a) requires disclosure of a material connection that might affect the weight or credibility of an endorsement, but says expressly that the disclosure “does not require the complete details of the connection.” Section 17(b) requires the amount. We treat 16 CFR Part 255 as the floor and never as the ceiling. “Clear and conspicuous” is a defined performance standard: difficult to miss and easily understandable by ordinary consumers (16 CFR 255.0(f)).
What we are not claiming. Whether the FTC would assert § 5 jurisdiction over issuer-paid securities promotion is unsettled: the exemptions at 15 U.S.C. 45(a)(2) do not exclude it, and in practice the SEC polices this conduct. We make no representation that the FTC has reviewed, cleared or approved anything we publish. The Trade Regulation Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465, effective 21 October 2024) is a binding rule carrying civil penalties and bars undisclosed insider reviews and testimonials. Any testimonial or client-quote content we publish is inside its scope.

Canadian requirements

Most Canadian guidance on promotional activity is addressed to issuers. Section 52(2) applies directly to the person conducting the promotion.

  • The binding rule.Section 52(2) of the Securities Act (R.S.B.C. 1996, c. 418) requires a person engaged in investor relations activities to ensure that every record disseminated as part of those activities clearly and conspicuously discloses that the record is issued by or on behalf of the issuer or security holder. That is an attribution requirement, separate from and additional to compensation disclosure.
  • The publisher carve-out does not cover us.The definition of investor relations activities excludes the publisher of a newspaper, news magazine or business or financial publication of general and regular paid circulation, distributed only to subscribers or purchasers for value, and only where the publisher or writer receives no consideration other than for acting as publisher or writer. Our publication is free and the issuers profiled pay us. We are a person engaged in investor relations activities under British Columbia law.
  • Section 52(1) is the issuer’s duty.An issuer that engages someone for investor relations activities must disclose the engagement, and on whose behalf it is undertaken, to anyone who inquires. We will confirm any engagement, and what we were paid for it, to anyone who asks.
  • CSA Staff Notice 51-356.Staff guidance addressed primarily to issuers, so it is not a direct legal duty on us. It names as problematic the paying of third parties to promote issuers on social media and investing blogs where those parties “do not disclose their agency, compensation and/or financial interest,” and expects issuers to prominently disclose when articles are paid for by the issuer. We disclose agency and compensation in the label and hold no financial interest. Read it in full here; it is also the reference standard cited on the limitations page.
  • Its scope note matters for small caps.51-356 says that although its examples come from the venture marketplace, its expectations apply to all issuers. Its companion instruments are National Policy 51-201 Disclosure Standards, CSA Multilateral Staff Notice 51-336 Issuers Using Mass Advertising, and CSA Staff Notice 51-348 Staff’s Review of Social Media Used by Reporting Issuers.

Scope of this page

  • Rules, not certifications.Where this page states a rule, it is a rule Richport Media Inc. holds itself to. No regulator has reviewed it, no third party audits it, and we hold no certification, registration or accreditation in connection with it.
  • Commitments and current practice.Part of this page describes how the business operates today; part describes what the first paid article will carry. The gap identifies the items not yet in place.
  • Not legal advice.Nothing here is legal advice to an issuer, a reader or anyone else. An issuer’s disclosure obligations are its own, and its counsel’s. Every article and headline we publish is approved in writing by the issuer and its counsel before it runs, market by market, and the issuer keeps a takedown right that survives approval — see the method.
  • The footer, on every page.Campaign-outcome and metric disclaimers — how the Market Liquidity Multiplier is computed, why the trading figures are conservative, what the financing references do and do not claim — sit in the footer of every page, including this one.
  • Advertising technology on this site.The analytics and advertising technology that runs on this website, and the choice offered about it, are described in the cookie notice and the privacy policy.
  • How we reach issuers.Where our business contact data comes from, and how to stop hearing from us, is set out in the data collection notice. Terms of use are on the terms page.
  • Asking us directly.Write to [email protected] for the compensation details behind any article we published, or for confirmation of an engagement. Richport Media Inc. answers for anyone who asks, including a regulator, and does not require a reason.
Richport Media Inc. A Puerto Rico corporation, 1225 Ave Ponce De Leon, PH 2020, San Juan, PR 00907, United States. Disclosure and compensation enquiries: [email protected].