Our regulatory posture

NakedPnL is a publisher of cryptographically verified trader performance data. We are not an investment adviser, broker, or asset manager — and we have built the product so we never need to be.

Last reviewed: April 10, 2026

What we are

A publisher of verified performance data

NakedPnL aggregates, verifies, and publishes third-party investment performance data submitted by institutional funds and individual traders. The data is sourced directly from exchange and brokerage accounts via read-only API connections authorized by the account holder.

Verification is cryptographic and auditable. Every daily snapshot is hashed using SHA-256 and chain-linked to the previous record. This creates a tamper-evident, append-only ledger of performance history that anyone can verify independently.

We do not generate, interpret, or editorialize the data. We compute time-weighted returns using the same methodology employed by institutional fund administrators, and we publish the results in a public registry ranked by verified return.

What we are not

Clear boundaries, by design

Not an investment adviser. We do not provide personalized recommendations about any security, commodity, or digital asset.

Not a broker or dealer. We do not execute trades, route orders, or hold customer funds.

Not an asset manager. We do not manage money or exercise discretion over any account.

Not a copy-trading platform. We do not enable users to mirror, auto-follow, or replicate any trader's positions. This is a permanent product commitment, enforced at the code level by compliance feature flags.

Not a signal service. We do not transmit trade alerts, entry/exit signals, or recommendations.

Not a research provider. We publish factual performance data, not opinions, forecasts, or analyst reports.

Legal basis, by jurisdiction

How we operate in each market

Jurisdiction	Our position	Primary basis
United States	Operating under the publisher's exemption	Section 202(a)(11)(D) of the Investment Advisers Act of 1940; Lowe v. SEC, 472 U.S. 181 (1985)
United Kingdom	Publishing information, not advice	FCA PERG 8.28 — league tables classified as information, not personal recommendation
European Union	Outside MiFID II investment advice scope	Article 4(1)(4) — no personal recommendation element
United Arab Emirates	Innovation-licensed publisher	DIFC Innovation License (planned 2026)
India	Statistical summary publisher	SEBI Research Analysts Regulations 2014, Regulation 2(w) exclusion

This reflects our analysis and is not legal advice. We have engaged or are engaging local counsel in each jurisdiction.

Verification scope

What we verify — and what we do not

We verify

Data integrity from the moment of API ingestion via SHA-256 hash chain

Tamper-evidence on all historical records

Basis-point-precision return calculations using time-weighted methodology

We do not verify

The trader's identity beyond the connected account

The source of funds in any connected account

Whether the trader's strategy is sound or appropriate

Future performance of any kind

See our Methodology and Disclaimers for full detail.

Compliance commitments

Features we will not build

The following capabilities are permanently disabled in our codebase via compliance feature flags. Each flag is protected by automated tests that fail the build if the flag is accidentally enabled.

No copy trading or auto-executionTriggers IA/CTA registration

No personalized recommendationsConstitutes investment advice

No broker affiliate links paired with performance dataFinancial promotion risk

No investor-trader matchingArranging deals in investments

Adding any of these features would require legal review and a public update to this page.

Data and privacy

How we handle your data

Public profiles require explicit, withdrawable consent (GDPR Article 7). Users choose whether their verified data appears on the registry.

Read-only API access only. We cannot place trades, withdraw funds, or modify your account — even if we wanted to.

Right to erasure honored within 30 days of request. Account deletion removes all personal data, credentials, and performance history.

See our full Privacy Policy.

Contact

Regulatory inquiries

We welcome contact from regulators, journalists, and counsel. For regulatory inquiries, contact compliance@nakedpnl.com. We respond within 5 business days.

Changelog

Date	Change
2026-04-10	Initial publication of regulatory posture page.