Code of Conduct

FPA Connect Terms of Use

Thanks for being part of FPA's community, FPA Connect. FPA™ Connect is an online discussion forum designed for FPA members to meet, interact, and share ideas with each other. It is not a forum in which FPA members, including registered representatives, who are subject to FINRA or the Securities Exchange Act of 1934, will do anything that could be characterized as promoting securities to each other or having communications intended to promote products or services to the public. 

This restriction is not intended to limit in any way the professional networking and educational advantages of this platform. Rather, it ensures that you and your firm are not subject to the FINRA Guidelines for Blogs and Social Networking Web Sites, Regulatory Notice 10-06, and 11-39 when using this online site. These Guidelines set forth, among other things, requirements for record keeping, supervision of interactive electronic communications (unscripted, interactive comments) and pre-approval of static communications (profile, background information and marketing mailers). 

Six simple rules help us create a positive environment – 1) Be nice.  2) Own your own words.  3) Keep it relevant.  4) Assume good intent.  5) Share.  Don't sell. (FPA Connect is a promotion-free zone)  6) Maintain high ethical standards.

FPA requires all participants to respect these six simple rules. There are other guidelines you need to be aware of, which follow below. So, give these a read and let's get started!

In order to preserve a climate that encourages both civil and fruitful dialogue, FPA Connect reserves the right to suspend or terminate participation on all lists for members who violate these rules. FPA reserves the right to immediately remove any postings it deems in violation of these Terms of Use.

FPA Knowledge Circles and communities thrive best when people work within the same framework. FPA determines the terms and conditions of your use of our services in these FPA Terms of Use and in other rules that we may place on our site.

By using FPA Connect, you accept and agree to be bound by the following terms and conditions. Nothing in the Terms of Use should be construed to confer any rights to third party beneficiaries. Please remember the following when utilizing FPA Connect:

1. When you register for FPA Connect you must provide true, accurate and complete registration information.
2. FPA Connect is a promotion-free platform.  No posting of outside events, seminars, conventions, sales, etc. is permitted.  FPA-centric events and communications posted to FPA Connect must first be approved by FPA staff prior to being shared or posted to the FPA Connect Forums and the FPA Connect Calendar. For questions, please contact:  [email protected].
3. Messages must maintain professional, moral and ethical standards.  Posting inaccurate/misleading/or false information will be met with immediate action by the Community Administrator. If an individual is notified that something they posted is in error and they do not remove the post or edit it immediately to rectify the infraction, they will be subject to the three-strike policy which can result in expulsion from FPA Connect.  Please review “FPA’s Right to Terminate” further in this document.
4. Messages should not be posted if they encourage or facilitate members to arrive at any agreement that either expressly or impliedly leads to price fixing, a boycott of another's business, or other conduct intended to illegally restrict free trade. Messages that encourage or facilitate an agreement about the following subjects are inappropriate and may be a violation of state and federal antitrust laws: prices, discounts, or terms or conditions of sale; salaries; profits, profit margins, or cost data; market shares, sales territories, or markets; allocation of customers or territories; or selection, rejection, or termination of customers or suppliers. *Please review the “Anti-Trust and Price Fixing” section later in this document. 
5. You may not harass, defame, abuse, stalk, threaten, advocate violence against other members or individuals or groups, or otherwise violate the legal rights (such as rights of privacy and publicity) of others. Do not post anything in your message that you would not want the world to see or that you would not want anyone to know came from you.
6. Members with conflicting or competing interests to those of FPA must provide transparency as to their affiliations/ backing organizations, so FPA Connect members can receive a full, fair and honest picture of where/why the comments are originating. (I.e. member of competing member organization)
7. You may not post content that is harmful to minors.
8. No profanity or sexually explicit language is allowed. You may not post content that is obscene, otherwise objectionable, or in violation of federal or state law.
9. You may not make job postings or solicitations on FPA Connect.  The appropriate place to do so is
10. You may not establish a link to any third-party site that you know or have reason to know contains false or misleading content.
11. You may not use any robot, spider, site search/retrieval application, or other device to retrieve or index any portion of FPA Connect or collect information about users for any unauthorized purpose.
12. You may not promote or provide instructional information about illegal activities or promote physical harm or injury against any group or individual.
13. Transmission of any viruses, worms, defects, Trojan horses, or any items of a destructive nature is strictly prohibited.
14. Please stay on topic. Although all groups are different, most groups appreciate it when you stay on topic. If you constantly stray from the topic you are negatively impacting the environment and may be removed from the group altogether.
15. You may not use FPA Connect for commercial, advertising purposes, or business communication purposes that would make you subject to FINRA's Guidelines on Social Networking Sites or Rule 17a-4(b) of the Securities Exchange Act of 1934 which requires certain business records to be maintained for at least three years. A registered representative is subject to FINRA's Guidelines and SEC Rule 17a-4(b) when he or she does anything that could be characterized as promoting securities to other registered representatives or by engaging in communications that are intended to promote products or services to the public. Further, you may not post messages that promote pyramid schemes, chain letters or disruptive commercial messages or advertisements, or anything else deemed prohibited.
16. We encourage you to have an authorized person from your firm review this website and confirm that your use will not be subject to the FINRA Guidelines on Social Networking Web Sites, and approve your participation in this website as being in accordance with any policies of the firm.
17. The content within FPA Connect is protected by copyright and other laws. FPA authorizes you to view and download a single copy of the content solely for your personal, non-commercial use. You may not sell or modify the content or reproduce, display, publicly perform, distribute, or otherwise use the content in any way for any public or commercial purpose without the written permission of FPA. To obtain FPA's permission to use any of the content on Connect please e-mail FPA Connect's administrator or other people designated by FPA.
18. You may not post content which violates any rights of any third party, including copyright, trademark, privacy, or other person or proprietary rights. 
19. You may not use FPA Connect for the purpose of storing and/or archiving files.
20. You cannot re-post or re-transmit content that belongs to another user without that user's permission, and under no circumstances should the content be provided to members of the public for the purpose of marketing securities or other activities that are regulated by FINRA and the SEC. This prohibition includes forwarding or sharing the emails that you may receive through FPA Connect group discussions, including the comments you may make or discussions you may initiate through FPA Connect. This prohibition is intended to ensure that the closed community of FPA Connect is maintained, and that discussions are not being shared with members of the public with whom communications are regulated by FINRA and the SEC. Posting content generated in FPA Connect to any other site is prohibited. Quoting portions of postings or entire postings in publications, news stories, or any venue in the public domain, including without limitation emails, is prohibited.
21. All data, text, information, links and other content, whether posted in public or private groups, is the sole responsibility of the person from which such content originated. FPA is not responsible for content that you (the user) publish, post, upload, distribute, disseminate or otherwise transmit via FPA Connect. Under no circumstances will FPA be liable in any way for any content, including, but not limited to, for any errors or omissions in any content, or for any loss or damage of any kind incurred as a result of the use of any content posted on FPA Connect. You agree that you will evaluate, and bear all risks associated with, the use of any content, including any reliance on the accuracy, completeness, or usefulness of such content. You understand that the technical processing and transmission of FPA Connect may involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.
22. FPA does not pre-screen, control, edit or endorse content made available through FPA Connect and has no obligation to monitor the content posted. If FPA discovers content that does not appear to conform to the Terms of Use, FPA may investigate and determine in its sole discretion whether to remove the content. FPA will have no liability or responsibility for performance or non-performance of such activities.
23. The Terms of Use of this service are subject to update by FPA at any time with or without notice. User can review the most current version of these Terms of Use online at any time.
24. FPA is not responsible for the opinions and information posted on this site by others. FPA disclaims all warranties with regard to information posted on this site, whether posted by FPA or any third party; this disclaimer includes all implied warranties of merchantability and fitness. In no event shall FPA be liable for any special, indirect, or consequential damages or any damages whatsoever resulting from loss of use, data, or profits, arising out of or in connection with the use or performance of any information posted on this site.
25. Do not post any information or other material protected by copyright without the permission of the copyright owner. By posting material, the posting party warrants and represents that he or she owns the copyright with respect to such material or has received permission from the copyright owner. In addition, the posting party grants FPA and users of this list the nonexclusive right and license to display, copy, publish, distribute, transmit, print, and use such information or other material.
26.  Impersonation feature:  Designated FPA Connect online administrators have the ability to impersonate FPA Connect member profiles while troubleshooting an item that members have requested help with. During the impersonation period, staff will not post on your behalf, make changes to your profile, subscribe you to anything, or make any other changes to your profile and online account. Our intent is to troubleshoot only, and FPA staff is held to strict guidelines on this behavior.

If you are unsure whether your content is consistent with these policies, please err on the side of caution and do not post your content in FPA Connect.

Anti-Trust and Price Fixing: 
For your safety and ours, FPA will not tolerate anti-trust or price-fixing posts made to FPA Connect.  All members are expected to read and adhere to FPA’s Antitrust Policy stated on .  

For a refresher of what is NOT allowed please reference these tips from the Federal Trade Commission:

“Price fixing relates not only to prices, but also to other terms that affect prices to consumers, such as shipping fees, warranties, discount programs, or financing rates. Antitrust scrutiny may occur when competitors discuss the following topics:
Present or future prices
Pricing policies
Terms or conditions of sale, including credit terms
Identity of customers
Allocation of customers or sales areas
Production quotas
R&D plans “

FPA's Right To Terminate
FPA Connect reserves the right to terminate or remove any content, Group or FPA Connect access without notice if (a) FPA believes that you have acted inconsistently with the spirit or the letter of the FPA Terms of Use; or (b) FPA believes you have violated or tried to violate the rights of others; or (c) for any reason (including, but not limited to, upon receipt of claims or allegations from third parties or authorities relating to such content). Please help us keep FPA Connect an enjoyable and positive experience. If you see content that violates our rules, please let us know by e-mailing the FPA Connect administrator.

Please be advised:  We adhere to the following "Three Strikes" Policy outlining consequences for participants who violate the Code of Conduct:

1. Upon the first violation, the participant will receive a written warning from an FPA staff member.
2. A second violation of a similar nature will result in a three-month suspension from FPA Connect.
3. A third violation will result in immediate and permanent suspension of all FPA Connect privileges.

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