Governance
Compliance Ledger
Every cap in the Investment Policy Statement, checked against today's actual portfolio. This isn't a claim that the rules are followed — it's a live scoreboard that can prove it, or catch it when they aren't.
Why this page exists
A written policy is only worth something if it's actually checked against reality, on a schedule, by someone with an incentive to look away. This page is that check. It updates whenever the Holdings page updates, and every breach stays listed here — including the ones I haven't fixed yet — until it's actually resolved, not until it's convenient to stop mentioning.
| Rule | Policy limit | Current | Status |
|---|---|---|---|
| Single-position cap | ≤ 10% at cost | SNDK at 7.94% of book | Compliant |
| Speculative sleeve cap | ≤ 25% of invested capital | 6.8% of book | Compliant |
| Leveraged / derivative sleeve cap | ≤ 5% of invested capital | 2.1% of book (NBIL) | Compliant |
| Core bucket — majority of book | > 50% of book | 63.6% of book | Compliant |
| Index hedge — always held | Ballast position required | 19.2% across SPY, VOO, QQQ, SCHD | Compliant |
| Single-theme clustering disclosure | Flag when it appears (no hard cap) | 60.93% of book in one AI-infrastructure/compute/power theme — full breakdown on Thematic Exposure | Disclosed |
| The Blackout Rule | No trades within 48hrs of scheduled earnings | No trade-execution timestamp data published yet | Not yet verifiable |
| The Holding Period | Core positions held ≥ 30 days from purchase | No trade-execution timestamp data published yet | Not yet verifiable |
The breach that just resolved — and why it doesn't count as a win
As of this update, SNDK sits at 7.94% of the book, comfortably under the 10% at-cost single-position cap it had been breaching earlier in July. Read that honestly: the position didn't come back under cap because the trim I said was owed since the June letter finally got executed — it never did. SNDK has continued to pull back in price (return on cost has fallen from roughly 257% at the peak to 151.41% now), which mechanically kept shrinking its weight. The position is still flagged Under Review rather than Active for exactly this reason. A cap satisfied by the market moving against a position is not evidence the discipline worked; it's evidence the position was one further leg higher away from a trim that still hasn't happened. If SNDK re-approaches 10% on a rally rather than a pullback, the same obligation applies again.
What this page won't do
It won't quietly stop listing a breach because it embarrasses me, and it won't round a number in my favor. If a rule stops being tracked here, that change itself should be explainable — not a silent removal. See Disclosures for the full data-sourcing and limitations statement.