Penny Stock Vetting Report

Overview

A Penny Stock Vetting Report is a paginated, twelve-section due-diligence document on a sub-$5 OTC / Pink / OTCQB / OTCQX or low-priced major-exchange listing. It is generated on demand from SEC EDGAR (free, all filings — 10-K, 10-Q, 8-K, Form 4 insider trades), OTC Markets free company info pages, FINRA BrokerCheck (for licensed promoters), the SEC enforcement actions database (free), public X/Twitter handles of named promoters, Reddit promotion patterns, paid-promotion-tracker databases, and Serper-driven press search. It takes three to five minutes to produce, costs 50 credits (about $20 USD), and is delivered as a shareable HTML report with a printable PDF view.

It is intended for a retail penny-stock investor doing pre-position Due Diligence, a short-seller doing pre-position research, an investigative journalist investigating pump-and-dump schemes, or an SEC enforcement researcher using the report as academic context (not as a customer).

The report is not a verdict on the stock. It is a structured presentation of the public regulatory record across four risk axes — business legitimacy, management track record, pump-pattern signals, regulatory cleanliness — for the reader to evaluate themselves against fraud-pattern signatures.

The Five Frameworks We Adopt

SEC Penny-Stock Disclosure Framework

The SEC’s penny-stock-specific disclosure framework (Rule 15g-1 through 15g-9, plus the Penny Stock Reform Act of 1990) defines what constitutes a penny stock and what disclosures are required. We anchor every report to these definitional criteria — sub-$5 share price, traded outside major exchanges (or recently moved off), and limited liquidity — and apply the SEC’s mandated risk warnings as the floor for our own disclaimer language.

ICD 203 — Analytic Standards (Office of the Director of National Intelligence)

The U.S. Intelligence Community’s Directive 203 defines nine tradecraft standards. We treat these as binding for every Penny Stock Vetting Report.

UK PHIA Probability Yardstick (UK Defence Intelligence)

Every probabilistic claim — pump-pattern probability, dilution-event probability, regulatory-action probability — is expressed using the seven-band PHIA yardstick paired with an analytical-confidence rating.

Executive Due Diligence Methodology (MentionFox)

Section 3 (Management Track Record Audit) applies the same Executive Due Diligence methodology that anchors the Executive Vetting Report (vertical 3 of the Due Diligence Platform): named-officer track record across prior public-company associations, prior SEC enforcement, prior FINRA actions, prior shell-company / reverse-merger involvement. Penny-stock fraud is overwhelmingly a recidivist behaviour — the same operators surface in multiple shell-company patterns over time.

Promoter Attribution Chain (MentionFox-original)

Section 7 (Promoter Attribution Chain) applies a MentionFox-original methodology. We identify named paid promoters of the subject stock, then for each promoter we audit their prior pump targets — what other penny stocks did they promote, and what happened to those stocks in the 90 / 180 / 365 days after promotion. The methodology surfaces clustering: when the same promoter network has a documented pattern of prior pumps that resolved in major drawdowns, the current promotion is itself a structural signal — irrespective of the underlying business.

The Twelve Sections of a Penny Stock Vetting Report

Promoter Attribution Chain — How We Apply It

The Promoter Attribution Chain is MentionFox-original methodology. The penny-stock pump-and-dump scheme depends on a small ecosystem of repeat operators: stock-promotion newsletters, X/Twitter influencers with paid-promotion arrangements, and Reddit accounts coordinated around price-movement windows. The methodology surfaces this network for each subject stock:

1. Identify named promoters. Every public-facing promotion mentions an entity (newsletter / X handle / Substack / Reddit username). We catalog each named promoter for the subject stock.
2. Audit prior promotion targets. For each named promoter, we surface their last 5-10 promoted stocks where the promotion is publicly retrievable. For each prior target, we look up the post-promotion outcome: did the stock drop 50%+ within 6 months? Was it SEC-halted? Was it delisted? Did it eventually recover?
3. Audit disclosure compliance. SEC Section 17(b) and FTC paid-endorsement rules require named promoters to disclose compensation, source of compensation, and total dollar value. Were these disclosures made? Were they prominent or buried in fine print?
4. FINRA history. If the promoter is a registered broker-dealer rep, surface their FINRA BrokerCheck record. Stock-promotion activity by registered reps is a separate compliance axis.
5. Cluster pattern. If multiple promoters of the subject stock share prior-pump targets, surface the cluster. Cluster signals are stronger than single-promoter signals.

The methodology surfaces signal; it does not generate verdicts. A stock can be promoted by a network with a poor track record AND still have a legitimate underlying business. The buyer applies their threshold.

Data Sources — Free Public Only

We deliberately use only free public data sources. The SEC EDGAR system is the primary data source — every public-company filing is free and immediately accessible, and SEC EDGAR primary documents (10-K, 10-Q, 8-K, Form 4) are higher-quality than any paid platform’s aggregated view because they are the original source of truth.

• SEC EDGAR — every public-company filing. Primary source of truth.
• OTC Markets free company info pages — for OTC / Pink / OTCQB / OTCQX listings.
• FINRA BrokerCheck — for licensed promoters and any officer with a broker-dealer registration.
• FINRA Disciplinary Actions Online — for FINRA enforcement.
• SEC enforcement actions database — free, comprehensive, primary source.
• State securities commissioner press releases — many penny-stock issuers are pursued at state level before federal action.
• Public X/Twitter handles of named promoters.
• Reddit r/pennystocks, r/wallstreetbets, r/Stocks — for promotion patterns.
• Substack / paid newsletter mentions — for compensated promotion.
• PromotionStockSecrets, BadDrip, OTC-promotion-tracker — public databases that catalog known stock-promotion campaigns.
• Serper — for general press / news search.

Honest Limits — what we do not do

Corrections Policy

Three commitments modeled on the BBC editorial corrections process:

1. Identification window. Errors flagged within thirty days of report generation are corrected on the canonical view URL within five business days.
2. Re-publication, not silent edit. Corrections preserve a redline diff between the original and corrected text, time-stamped, with a one-line explanation.
3. Subject right of reply. The company named in any Vetting Report may submit a one-paragraph factual rebuttal to corrections@mentionfox.com. Verifiable rebuttals attach to the report alongside the original section.

Data integrity floor — ALCOA. Every Penny Stock Vetting Report carries an ALCOA Methodology footer: each factual claim is Attributable to a cited source, presented in Legible plain language, marked with the date it was Contemporaneously verified, sourced from the Original primary record where available, and Accurately reflects the underlying evidence.