Disclosures & Marketing Rule Information

1. Purpose and Scope

This page explains the nature of Capital Honors editorial recognition, the separation between selection and optional paid services, limitations on the information published by Capital Honors, and factual information that may assist regulated firms evaluating use of a Capital Honors recognition in advertising.

These materials are informational. They are not legal advice, SEC approval, FINRA approval, a regulatory filing, or a determination that any particular advertisement or use of a recognition complies with SEC Rule 206(4)-1 or any other law, rule, regulation, or firm policy.

2. Editorial Recognition

Capital Honors publishes professional and firm profiles and annual editorial recognition programs concerning private equity, venture capital, growth equity, private credit, asset management, family office, institutional investment, and related private-capital professionals and organizations.

Recognition decisions are editorial. Capital Honors evaluates candidates under category-specific criteria and editorial judgment for the applicable program period. A recognition is not investment advice, an investment recommendation, regulatory verification, due diligence, a credit rating, or an endorsement of any fund, security, strategy, firm, or professional.

3. No Purchase Necessary; Commercial Separation

No purchase or payment is required to be nominated, considered, evaluated, selected, or to retain a valid Capital Honors recognition. Purchasing or declining an optional profile, promotional, physical award, premium creative, or enhanced-placement service does not affect editorial selection or continued recognition.

Selection does not require payment, and a complimentary registry listing is provided at no cost. Capital Honors badges, insignia, logos, graphics, and other branded recognition assets are separate from the recognition itself and are licensed only as part of an applicable paid recognition package, alongside deliverables such as an editorial profile, a physical award, and inclusion in a syndicated recognition announcement. Enhanced or sponsored placement is labeled where displayed.

4. Methodology and Sources

Capital Honors evaluates candidates using category-specific editorial criteria. Sources may include nominations, public regulatory records, company and fund announcements, reputable data services, professional biographies, transaction reporting, and materials a candidate is authorized to submit. The availability, completeness, and comparability of information vary by candidate and category.

The editorial process generally includes candidate discovery, eligibility review, information review, criteria assessment, a human editorial decision, and commercial separation after the recognition decision. The applicable Methodology page identifies the criteria and program framework for the relevant recognition cycle.

Capital Honors does not represent that every candidate is evaluated using identical data inputs or a uniform quantitative score. Unless a specific program expressly uses a documented scoring system, terms such as "composite score," "verified track record," "independent verification," or "approval of credentials" should not be inferred from a Capital Honors recognition.

5. Financial, Performance, and Regulatory Information

Financial and performance information, including AUM, fund size, returns, transaction values, or related metrics, may be supplied by the profiled firm or derived from public or third-party sources. Capital Honors does not independently audit these figures unless a specific statement expressly identifies the audited or verified scope.

Capital Honors does not continuously verify regulatory standing, investor relationships, licensing, registrations, or disciplinary status unless a specific profile field expressly states the source and date checked. Past performance does not guarantee future results. Investors and counterparties should conduct independent due diligence.

6. SEC Investment Adviser Marketing Rule and Third-Party Ratings

When an SEC-registered or required-to-be-registered investment adviser uses a Capital Honors designation in an advertisement, the designation may constitute a "third-party rating" for purposes of SEC Rule 206(4)-1 depending on the facts and use. The Marketing Rule imposes requirements on the adviser using the rating, including general anti-misleading standards and specific conditions for third-party ratings.

Where Rule 206(4)-1(c) applies, the adviser must have the reasonable basis required by the rule concerning any questionnaire or survey used to prepare the rating, and the advertisement must clearly and prominently disclose, or the adviser must reasonably believe the rating itself clearly and prominently discloses: the date of the rating and the period on which it was based; the identity of the third party that created and tabulated the rating; and, where applicable, compensation provided directly or indirectly in connection with obtaining or using the rating.

Capital Honors does not approve an adviser’s advertisement or guarantee Marketing Rule compliance. Each adviser should have its own compliance and legal personnel review the recognition, methodology documentation, applicable compensation facts, disclosure placement, audience, and use before publication.

Where a regulated adviser uses the badge and Rule 206(4)-1 third-party-rating requirements apply, the applicable date, period, provider, and compensation disclosure should be clear and prominent in the advertisement itself. Do not rely on this page as the only place the required information appears.

7. Questionnaires and Surveys

Capital Honors does not represent that every recognition program uses a questionnaire or survey. If a questionnaire or survey is used in preparing a recognition that may be treated as a third-party rating, Capital Honors will identify that fact in the applicable methodology or compliance documentation and will not intentionally structure the instrument to produce a predetermined favorable result. Any adviser relying on the recognition remains responsible for developing the reasonable basis required by Rule 206(4)-1(c).

8. Compensation and Optional Paid Relationships

Selection can occur with no payment. A later purchase does not retroactively make the editorial selection purchased. However, compensation connected with obtaining or using a recognition can be material under securities and advertising rules. For that reason, Capital Honors maintains commercial-relationship records and provides factual compensation-status language for use in a recipient’s compliance review.

A recognized firm or professional may purchase optional profile, promotional, physical award, premium creative, analytics, or enhanced-placement services after selection. Payment does not determine the award. Where an adviser uses the recognition in advertising, the adviser should determine whether the paid relationship must be clearly and prominently disclosed and should use a disclosure that matches the actual transaction facts.

9. Model Disclosure Legends for Regulated Adviser Use

The following samples are factual templates for review and modification by the recipient’s chief compliance officer or legal counsel. They are not pre-approved regulatory language and should not be used unless the bracketed facts are accurate for the specific recipient.

Which legend applies. Capital Honors badges and other branded recognition assets are licensed only as part of a paid package. A recipient displaying a Capital Honors badge has therefore provided compensation in connection with using the recognition and should use one of the compensated legends below. The no-compensation legend is available only to a recipient who has purchased nothing and is stating the fact of recognition in words rather than displaying a badge.

10. Recipient-Specific Documentation

For each regulated recipient, the Capital Honors compliance record should be able to provide the exact recognition title and recipient, award date, evaluation period, identity of Capital Honors / Silent West as creator and tabulator, methodology version, whether questionnaires or surveys were used, applicable criteria, commercial relationship and compensation status, and the factual disclosure legend appropriate to that recipient.

These records are intended to assist the recipient’s internal review. They are not a legal opinion or representation that the recipient has satisfied its own recordkeeping, substantiation, disclosure, approval, or supervision obligations.

11. Broker-Dealers and Other Regulated Firms

Broker-dealers and associated persons may be subject to FINRA Rule 2210, SEC rules, state securities law, firm supervisory procedures, and other communications requirements. Capital Honors does not determine whether a communication is fair and balanced, whether filing or principal approval is required, or whether a payment relationship must be disclosed under rules applicable to the recipient.

Other private-capital firms may be exempt from or outside particular federal adviser requirements but remain subject to antifraud, advertising, contractual, professional, or state-law obligations. Each recipient is responsible for identifying the rules that apply to its own status and use.

12. Private Funds and Investment Context

The regulatory treatment of an advertisement depends in part on the status of the adviser and the communication, not merely on whether the subject is labeled private equity, venture capital, private credit, or another private-market category. Capital Honors does not advise investors on whether to invest in a private fund and does not evaluate suitability for any investor.

13. Professional Inquiries and No Transaction Intermediation

Visitors may submit professional inquiries through Capital Honors. By submitting an inquiry intended for a listed professional or firm, the visitor authorizes Capital Honors to transmit the contact information and message to that recipient and to service providers used to process the request.

Capital Honors does not verify whether an inquirer is accredited, qualified, institutional, or otherwise eligible to invest; does not recommend an investment or manager; does not negotiate offering or transaction terms; does not participate in securities sales; and does not guarantee that a recipient will respond. Public inquiry forms should not be used to transmit subscription documents, account information, confidential offering materials, or material nonpublic information.

14. Confidential and Material Nonpublic Information

Capital Honors is not intended to receive material nonpublic information, confidential offering documents, investor identities, subscription materials, investor account information, portfolio-company nonpublic information, trade secrets, or information subject to third-party confidentiality obligations through public nomination, profile, or inquiry forms. Submit only information that is public or that you are authorized to disclose for the stated purpose.

15. No SEC, FINRA, or Regulator Approval

Capital Honors has not been approved, endorsed, certified, or designated by the SEC, FINRA, any state securities regulator, or any governmental authority as a compliance provider, investment adviser, broker-dealer, rating agency, due-diligence service, or securities offering platform. References to SEC Rule 206(4)-1 describe a compliance issue that may apply to a recipient’s use of recognition; they do not imply regulatory approval of Capital Honors or any recipient.

16. Corrections and Questions

If a Capital Honors profile or recognition record contains a materially inaccurate fact, submit a documented correction request through the Site’s correction or contact process. Compliance teams seeking program-period, methodology, or commercial-relationship information for a recognized firm may use the contact below.

Capital Honors compliance and correction contact: Hello@CapitalHonors.com, or Silent West d/b/a Capital Honors, 605 W 9th St Ste 1100, Austin, TX 78701.