Reg FD position

Mediaberry does not generate, distribute, or facilitate the selective disclosure of material non-public information. We ingest only publicly available retail-investor conversation, we deliver analysis to a single subscribing IRO (and their team), and we do not transmit information from the issuer's account to the public.

The information flow is one-directional and inbound: public retail commentary → Mediaberry analysis → the IRO's inbox. There is no path from Mediaberry to a securities analyst, shareholder, or media outlet that the IRO does not personally control.

Regulation Fair Disclosure (17 CFR 243.100-103) prohibits a public company, or a person acting on its behalf, from intentionally selectively disclosing material non-public information to securities-market professionals or to shareholders likely to trade on it, without simultaneously making it public. The trigger is selective disclosure of MNPI, by the issuer, to specified recipients.

Mediaberry is not the issuer.Reg FD applies to the company and persons acting on its behalf. “Persons acting on behalf of the issuer” can include IR vendors when they speak to the market on the issuer's behalf — which Mediaberry never does. We deliver only inbound analysis to the IRO; we do not author, draft, or distribute communications to analysts, shareholders, or media.

We do not transmit issuer information out of the IRO's account. Briefs, alerts, and other deliverables go only to the subscribing IRO and the team members they invite. There is no newsletter, public feed, or third-party syndication of any customer's data.

Inputs are public, with one customer-controlled exception. Mediaberry ingests posts from public retail-investor platforms — all public commentary. We do not ingest internal documents, draft press releases, or pre-publication transcripts — except where the IRO chooses to paste such context into Mediaberry's optional “Context” fields (e.g., Talking Points, Vulnerability Assessment). When this happens, the resulting AI output is delivered only to the IRO and their invited team members; it is not retained for model training and is not shared outside the customer's account. IROs should not paste material non-public information into Mediaberry unless their internal policy permits sharing that information with third-party vendors under standard SaaS confidentiality terms.

AI synthesis of public data is not, on its own, MNPI — though edge cases warrant judgment. Our outputs (sentiment scores, topic clusters, threat-vector analyses, etc.) are derived from public posts and interpret information that is already public. If a synthesis correlates public signals into an inference that an issuer or third party considers material and non-public (e.g., an inferred institutional position not yet disclosed), customers should treat that inference with the same Reg FD discipline they would apply to any internal analyst note. The IRO's judgment governs.

IROs using Mediaberry should still apply their standard Reg FD discipline when forwarding or quoting Mediaberry output to outside parties. Specifically:

• Treat the IRO's own internal context — supplied to talking points or vulnerability assessments — as MNPI if it would be MNPI in any other channel. Don't paste material non-public information into the “Context” field of any Mediaberry feature and then forward the output.
• When forwarding a brief or talking-point memo to your CEO or CFO, treat it as internal preparation material. Do not redistribute to analysts or shareholders.
• If a brief surfaces an active rumor about your company, follow your standard Reg FD response procedure (no comment / public clarification) — the brief itself doesn't change that calculus.

Customer accounts are isolated by design via Postgres row-level security. One IRO cannot see another IRO's tickers, mentions, briefs, talking points, or assessments. Mediaberry employees access customer data only when needed to deliver the service or respond to a support request, and access is logged.

This memo reflects Mediaberry's current understanding of how its platform interacts with Regulation FD. It is not legal advice, does not create an attorney-client relationship, and should not be relied upon as a substitute for advice from your own securities counsel. Regulatory interpretation may evolve; we will update this page if our analysis changes.

For specific Reg FD or compliance questions, email legal@mediaberry.com and we'll connect you with the right person.