Independence and disclosures

Charterbend writes about a bank. Three questions follow from that, and a reader is entitled to the answers before reading a word of the analysis: whether this site is a bank, whether it is giving advice, and who is paying for it. The answers are below, in the order they matter.

Charterbend is not a bank

Charterbend is not a bank. It does not accept deposits, and nothing on this site is insured by the FDIC.

Deposit insurance is administered by the Federal Deposit Insurance Corporation and covers deposit accounts at insured banks. It has nothing to do with a website. There is no account here to open, no balance to see, no money to move, and nothing that could be insured even in principle.

The governing text is 12 CFR § 328.102, and paragraph (a)(2) is the one that matters for a publication:

“No person may represent or imply that any Uninsured Financial Product is insured or guaranteed by the FDIC by using FDIC-Associated Terms or by using FDIC-Associated Images as part of an Advertisement, solicitation, or other publication or dissemination.”

12 CFR § 328.102(a)(2) · subpart B in force since April 1, 2024 · law.cornell.edu

So the rule of the house is narrow and absolute. No official sign, seal, badge, or logo of that agency appears anywhere on this site — not in the header, not in the footer, not as a trust mark, not as an icon. The publication never describes itself as insured, guaranteed, or protected. The name of the agency appears only in running text, where it is named as the source of a register or as the insurer of a named bank’s deposits, and it carries a link when it does.

One distinction is worth stating plainly because it is easy to get wrong, and this project got it wrong once in draft. Chartering, supervision, and deposit insurance are three separate jobs done by three different agencies, and for a single bank the answer to each can change over time. A page here that names any of the three names the register it was read from, and the date it was read.

Charterbend does not provide investment advice

Charterbend does not provide investment advice. It does not rate, recommend or value any security or institution, and nothing here is an offer or a solicitation to buy or sell anything.

What the publication does instead is narrower and duller: it reads a filed document and says what the document contains. There are no target prices, no ratings, no scores, no league tables, and no answer to the question of whether an institution is a good one — that question is not asked here, and the documents do not answer it.

Three editorial rules follow, and they are rules of construction rather than a disclaimer.

• No page addresses the circumstances of a reader. There is no calculator, no “how much,” and no assessment of whether anything suits anybody. The voice is institutional third person throughout.
• The publication takes no money from any institution it covers, sells no advertising, carries no affiliate links, and publishes no sponsored material.
• Pieces are dated, are released by rubric, and are not timed to market activity. The record tracks documents that have been filed, not price movements and not announcements of things that have yet to happen.

Behind those rules sits a statutory exclusion. The Investment Advisers Act excludes from the definition of an investment adviser “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 by the Supreme Court in Lowe v. SEC, 472 U.S. 181 (1985). The exclusion is treated here as a second line of defense and not the first: a publication that gives no advice at all never needs to reach it.

Nobody pays for coverage

These are the positions of the publication. They are printed here and on the masthead in the same words.

• The publication is funded by its owner and by research commissioned from it. It has no investors, no grants and no sponsors.
• It carries no advertising, no affiliate links, no sponsored content and no paid placement of any kind.
• No institution it covers has paid for coverage, and none ever will.
• No institution it covers may commission work from it either, and no commission may be used to obtain coverage, prevent it, or change it.
• Commissioned work is never published here, is never a source for anything that is, and has never changed a word of what is.
• The editor, the writers and members of their households hold no securities of any institution the publication covers, and do not trade them. A broad index fund that happens to contain such a security is disclosed as a category and is not treated as a position.
• The publication seeks no non-public information and uses none.

Nothing on this site is for sale. There is no subscription, no paywall, no tip jar and no membership, and every page is free to read. The publication is paid for in two ways instead, and both are named rather than left to be guessed at: its owner funds it, and the desk takes commissions — document work done to order for whoever asks, which is never published here. What may be commissioned, what will not be at any price, and who may not commission anything are all set out on the commissioned research page.

Securities held by the editor and the writers

The fourth position above is the one that does the most work, so it is set out here in full rather than in a line.

• Who it binds. The responsible editor, every staff writer, and the members of their households. Not only the author of the piece in question.
• What it forbids. Holding or trading the securities of any organization this publication writes about. Not holding them while also writing, and not trading them in a window around publication — holding them at all, at any time, whether or not anything is being written.
• Why it is permanent. A blackout window would imply that a position is acceptable outside the window. It is not. The rule runs continuously, which also means there is no window to test, no date to argue about, and nothing to police.
• The one exception, and it is a disclosure rather than an exception. A broad index fund can contain such a security without the holder choosing it or being able to exclude it. That is disclosed here as a category — a holding in a broad market index fund — and it is not treated as a position in any named institution.
• Non-public information. None is sought and none is accepted. Regulation FD binds an issuer rather than a publication, but trading on misappropriated non-public information binds anyone at all. Material offered “in confidence” is neither published nor used, and no piece here depends on anything that is not already public.

The reason is older than the site. Writing about a security while holding a position in it, without disclosing the position, is the conduct the Supreme Court treated as fraud in SEC v. Capital Gains Research Bureau, Inc., 375 U.S. 180 (1963). There is a second reason that matters more in practice: a position destroys the “disinterested commentary” that the publisher exclusion above rests on. The two questions are really one question.

Not affiliated with anything it covers

Charterbend is an independent publication. It is not affiliated with, endorsed by, or sponsored by Renasant Bank, Renasant Corporation, or any institution it covers.

That line stands in the footer of every page of this site, above the links rather than in fine print below them. It is the reason the site uses only the plain word-name of an institution and never its logo, its typeface, its colors, its icon, or a photograph of its premises; the reason the name of an institution appears in no domain, no wordmark, no mailbox address, and no site name; and the reason the publication buys no search keywords carrying an institution’s brand.

What would have to be disclosed if any of this changed

None of the following has happened. They are listed because the obligation attaches the moment one of them does, and because an operator who inherits this site should be able to see the cost before making the choice.

• Payment for a piece describing a security. Section 17(b) of the Securities Act, 15 U.S.C. § 77q(b), makes it unlawful to publish a description of a security for consideration received directly or indirectly from an issuer, an underwriter, or a dealer without disclosing both the fact of the payment and its amount. The disclosure belongs in the piece, not only on a policy page.
• An affiliate link, gifted access, a paid placement, or a free subscription from a covered institution. The Endorsement Guides, 16 CFR Part 255, require a material connection to be disclosed clearly and conspicuously, next to the link itself rather than on a page elsewhere. The publisher exclusion described above also stops holding at that point, so a single affiliate link is a decision about the shape of the whole site.
• A securities position, however it arose. It would be disclosed on this page and in every piece touching that institution, with the date it arose — and it would end the claim of disinterested commentary while it lasted.
• User reviews, comments, or uploads. Reviews are forbidden outright by the standards. Comments and uploads would change the legal position of the site in a second way, described on the terms page.