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 9.70% of book | Compliant |
| Speculative sleeve cap | ≤ 25% of invested capital | 5.60% of book | Compliant |
| Leveraged / derivative sleeve cap | ≤ 5% of invested capital | 2.25% of book (NBIL) | Compliant |
| Core bucket — majority of book | > 50% of book | 62.84% of book | Compliant |
| Index hedge — always held | Ballast position required | 17.59% across SPY, VOO, QQQ, SCHD | Compliant |
| Single-theme clustering disclosure | Flag when it appears (no hard cap) | 61.49% 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 has receded; the process issue has not
At September 29, 2026 close, SNDK is 9.70% of the book and therefore below the written 10% limit. The change came from market prices, not the trim promised in June. The rule is currently compliant, while the unexecuted commitment remains documented as a process failure.
The position remains Under Review. This ledger distinguishes the current numerical result from the decision process that produced it.
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.