Regulatory and methodology disclosures.
Last updated: 2026-06-02. This document is in active draft; the firm is finalising it with external counsel. Questions may be sent to legal@foliox.app.
What this portal is
Vercis is a non-discretionary research portal operated by FolioX, a Canadian sole-founder research entity (incorporation pending). It publishes pre-registered systematic allocation models, macro signal output, and portfolio diagnostic tooling. It does not custody assets, does not execute trades, does not manage money on behalf of subscribers, and does not operate any pooled vehicle.
What this portal is not
- Not personalised investment advice.The research published in the portal does not take into account any individual subscriber's financial situation, tax position, risk tolerance, or investment objectives. Subscribers integrate the research into their own investment process; allocation decisions remain the subscriber's responsibility.
- Not a recommendation to transact. Signal states (DEFAULT / DEFENSIVE, holding tickers, allocation weights) are model output. They are not buy, sell, or hold recommendations on any specific security and are not intended as instructions to trade.
- Not an offer or solicitation. Nothing on the portal constitutes an offer to sell, or solicitation of an offer to buy, any security or investment product in any jurisdiction.
- Not an investment-adviser relationship. FolioX is not registered as an investment adviser, a portfolio manager, a CTA, or any other financial intermediary in any jurisdiction. No fiduciary or advisory relationship is created by subscription or access.
Regulatory framing
The research is published under the non-discretionary research exemptions of:
- Canada — Ontario Securities Commission (OSC). The research is published as non-discretionary financial research. It does not constitute advice for which adviser registration would be required under National Instrument 31-103. A fuller regulatory-framework subpage is in preparation.
- United States — SEC research-publisher regime.The research is published as non-discretionary financial publication consistent with the publishers' exclusion from the definition of investment adviser under Section 202(a)(11)(D) of the Investment Advisers Act of 1940 and the line of interpretive guidance following Lowe v. SEC (472 U.S. 181, 1985). Research is impersonal, of regular and general circulation, and not promotional in nature.
External counsel review of the production regulatory framing is in progress.
Methodology and validation
Each allocation model is shipped with a pre-registration document that fixes the specification (signal definitions, benchmarks, acceptance gates, evaluation dates) prior to in-sample evaluation. A 36-month forward out-of-sample firewall begins at production deployment; no parameter, benchmark, or signal-definition revision is permitted during the firewall window without resetting the OOS clock.
Acceptance gates are Bonferroni-corrected for multiple- comparison testing across the variant family. Walk-forward splits, Carhart 4-factor attribution, robustness grids, and named stress-regime sweeps are documented in-portal alongside each model's Methodology, Backtest, and Limitations tabs.
Where the in-sample backtest uses synthetic constructions for pre-inception ETF history, the methodology page identifies the synthetic construction explicitly. Where the simulation engine uses a simplified trigger that differs from the production trigger (currently the case for the Event-Risk NAV simulation), the difference is flagged on the surface that displays the output.
Backtest and forward-looking statements
All backtest results presented on the portal are in-sample until the published H1 evaluation date for each model. Backtest results have inherent limitations: they do not reflect actual trading, do not necessarily account for the impact of material economic and market factors on real-money execution, and benefit from hindsight in the choice of strategy specification. Hypothetical results are not indicative of future results, and there is no representation that any subscriber will achieve results similar to those shown.
Any forward-looking statements on the portal — including monthly commentary — reflect the firm's view at the time of publication and are subject to change without notice as new data becomes available. Forward- looking statements involve known and unknown risks and uncertainties that may cause actual outcomes to differ materially.
Conflicts of interest
FolioX does not custody assets, does not earn brokerage, does not receive remuneration from product issuers, and does not operate any pooled vehicle. The firm has no undisclosed economic interest in the ETFs or securities referenced in any of the allocation models. The firm and its principal may, from time to time, hold positions in the ETFs referenced in the allocation models in their personal accounts; these positions are disclosed in regulatory filings as required and do not influence the published signal output.
Data sources and third-party content
Signal-pipeline inputs include FRED, Sharadar, yfinance, the CBOE, ICE BofA, Kalshi, and Polymarket. Monthly commentary is generated by Anthropic's Claude model with web-search sourcing; sources are cited inline and are available to subscribers as an expandable list at the bottom of each commentary. Third-party data is provided under the respective vendor's licence terms; the firm makes no representation as to the accuracy or completeness of third-party data.
Privacy and terms
The firm's privacy practices are described in the Privacy Policy. The terms governing access to the portal are described in the Terms of Use.
Changes
These disclosures will be updated as the regulatory framing is finalised with counsel and as the model catalogue and data-source roster evolve. Material changes will be notified to active subscribers at least 14 days before taking effect.