Fund policies

An Investment Policy Statement, or IPS, is a fund's own rulebook: a written promise about what it may trade, how much risk it may take, and what it measures itself against.

Every real investment fund writes one before it takes in a dollar, then holds itself to it.

We publish ours so the promise means something: anyone can check what a fund said it would do against what it actually did.

You do not need any finance background to read what follows.

Unfamiliar terms are explained the first time they come up, right where they are used.

These policies describe an educational paper-trading simulation. They are not an offer to invest and do not authorize real-money trading.

Glossary

IPS
Short for Investment Policy Statement: a fund's own rulebook. It states what the fund may trade, how much risk it may take, and what it measures itself against.
Benchmark
The outside index a fund measures its own return against, so a gain or loss means something.
Tracking error
How far a fund's return has drifted from its benchmark's return over time.
Drawdown ladder
The platform's automatic response to a losing streak: a fund's allocation is halved at one loss threshold and frozen for review at a deeper one, enforced by the platform, not by discretion.

How we operate

  • IPS changes are audit-logged.
  • Every trade is journaled.
  • The drawdown ladder is enforced by the platform, not by discretion.
  • A post-mortem is required after a book freeze, before it can restart.

Account and season policy

Every member trades on a single account funded with simulated capital only, never real money. A leadership-approved reset of a book is logged and the prior record is kept and presented here as an archived season, never deleted. Any skill-based forecasting league offered on the platform is scored in points only; no real money is ever involved there either. See our Terms of Use and Privacy Policy for the full policy.

DBC Ballast

A conservative, income-oriented anchor of high-quality dividend payers and defensive ETFs - designed to dampen program volatility and deliver steady yield.

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Mandate: Income defensive · Benchmark: Schwab US Dividend Equity ETF

Position limit 8% · Max drawdown 15% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

SCHD-like total return at lower drawdown with yield at or above the benchmark; tracking error 2-4% vs SCHD, volatility under 10%.

Risk tolerance

Low. Mega-cap defensives, no leverage or shorts; single position <=8%. Hard drawdown -15% re-underwrites and suspends new buys, no forced beta selling.

Time horizon

3-7 years.

Rebalancing

Quarterly rebalance; reinvest income. No forced selling solely due to market drawdown.

Liquidity

Mega-cap and large ETFs; fully liquid.

Benchmark policy

SCHD total return; success = comparable return at lower drawdown and equal-or-higher yield.

Review

Quarterly dividend-safety and drawdown review; -15% hard drawdown re-underwrites and suspends new buys.

Asset allocation

  • US Equity / ETF83% (60-95%)
  • Cash17% (5-40%)

Target positions

SCHD +12%JNJ +8%PG +8%KO +8%PEP +8%VZ +7%HD +8%ABBV +8%XLU +8%XLP +8%

Permitted instruments

  • high-quality dividend equities (mkt-cap >= $5B)
  • defensive/dividend ETFs (single <= 12%)

Prohibited activities

  • short selling
  • leverage
  • single position > 8%
  • names below $5B market cap

Risk limits

Concentration limit
8%
Max gross exposure
95%
Drawdown limit
15%

DBC Catalyst

Capture defined-catalyst situations - mergers, spinoffs, restructurings, index and earnings events - where outcomes are event-driven rather than market-driven.

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Mandate: Event driven · Benchmark: S&P 500

Position limit 8% · Max drawdown 18% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

Merger-arb-like absolute return with low SPY correlation (<0.4); target volatility 6-10%.

Risk tolerance

Moderate. Deal/event risk sized by probability times downside; single position <=8%, gross <=80%. Hard drawdown -18% de-grosses.

Time horizon

Event-dependent (weeks to months).

Rebalancing

Positions added and removed as catalysts resolve; holdings are analyst/event-driven, not a fixed target list.

Liquidity

Avoid illiquid deal stubs; each position <= 15% of 20-day ADV.

Benchmark policy

Primary benchmark MNA (merger-arb ETF); SPY secondary as market reference. Success = absolute return with SPY correlation below 0.4.

Review

Weekly catalyst calendar and deal-risk review. Every event position must record catalyst date/window, expected upside, expected downside, probability-weighted return, and an explicit exit rule before deployment.

Asset allocation

  • Event Equity (long)34% (0-60%)
  • Event Equity (short)6% (0-30%)
  • Cash60% (20-100%)

Permitted instruments

  • US-listed event equity (risk-arb longs, event shorts, borrowable)
  • cash

Prohibited activities

  • positions without complete event metadata (date, upside, downside, prob-weighted return, exit)
  • illiquid deal stubs
  • single position > 8%
  • gross > 80%

Risk limits

Concentration limit
8%
Max gross exposure
80%
Drawdown limit
18%

DBC Contra

Mandate: Short bias

Policy statement pending. This fund has not yet published a completed Investment Policy Statement.

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DBC Core Equity

Own a diversified book of high-quality, durable-growth US large caps that compound through cycles; the program's core equity sleeve and a fundamental-quality training ground. By construction it tilts to mega-cap quality/growth, monitored under the program theme limit.

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Mandate: Long only · Benchmark: S&P 500

Position limit 10% · Max drawdown 20% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

Beat SPY by 100-300 bps annualized over a full cycle at comparable or lower drawdown; tracking error 3-6% vs SPY.

Risk tolerance

Moderate. Full market beta accepted; single-name (<=10%) and sector (<=30%) concentration capped. Hard drawdown -20% triggers re-underwrite and suspension of new buys, not forced beta selling.

Time horizon

3-5 years, full market cycle.

Rebalancing

Monthly drift review; trim any name above 10%, top up underweights toward target. No forced selling solely due to market drawdown.

Liquidity

Large-cap only; every position fully exitable within one trading session.

Benchmark policy

SPY total return. Success measured on risk-adjusted excess return and drawdown vs SPY.

Review

Monthly performance and IPS-compliance review; quarterly thesis refresh. Hard -20% drawdown forces position-by-position re-underwrite and a new-buy suspension until review completes.

Asset allocation

  • US Equity88% (80-100%)
  • Cash12% (0-20%)

Target positions

AAPL +7%MSFT +7%NVDA +6%GOOGL +6%AMZN +6%META +6%V +6%MA +5%UNH +6%COST +6%HD +5%LLY +6%AVGO +5%JPM +6%LIN +5%

Permitted instruments

  • US-listed common equity
  • broad equity ETFs (<=15% single, <=20% gross)

Prohibited activities

  • short selling
  • leverage/margin
  • options
  • single ETF > 15%
  • names below $2B market cap

Risk limits

Concentration limit
10%
Max gross exposure
100%
Drawdown limit
20%

DBC Deep Value

A concentrated, contrarian book of statistically cheap, out-of-favor small/mid caps trading below intrinsic value - the program's high-conviction value sleeve.

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Mandate: Deep value · Benchmark: Russell 2000 Value

Position limit 20% · Max drawdown 30% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

Beat IWN (small-cap value) by 300-600 bps over a cycle, accepting a lumpier path; tracking error 8-15% vs IWN.

Risk tolerance

High. Concentration, small-cap illiquidity and value-trap risk, managed by a 15% normal / 20% committee position cap, balance-sheet screens and ADV limits. Hard drawdown -30% cuts the weakest names.

Time horizon

2-4 years.

Rebalancing

Re-balanced on thesis or valuation realization; 15% normal single-name cap, 20% only with committee sign-off. A 7th net-net name is added after a live small-cap screen.

Liquidity

Small/mid caps sized to liquidity: each position <= 8% of 20-day ADV; build and exit staggered over at least 5 sessions; min price $5, mkt-cap >= $150M.

Benchmark policy

IWN total return; success = excess return over a full cycle accepting higher tracking error.

Review

Quarterly thesis and hard valuation re-underwrite; -25% soft (re-underwrite) / -30% hard (cut weakest two) drawdown triggers. Every name verified for live status and ADV before sizing.

Asset allocation

  • US Equity (small/mid value)87% (50-100%)
  • Cash13% (0-50%)

Target positions

CLF +15%MAC +14%ZION +13%VTRS +12%BBWI +12%IEP +11%

Permitted instruments

  • US-listed common equity (small/mid value, mkt-cap >= $150M)
  • cash

Prohibited activities

  • short selling
  • leverage
  • position > 20% even with committee approval
  • names where a full exit exceeds 3 days ADV

Risk limits

Concentration limit
20%
Max gross exposure
100%
Drawdown limit
30%
Max illiquid exposure
100%

DBC Digital

A long-only digital-asset book anchored in large-cap crypto, giving the program measured exposure to the asset class with strict concentration in the most liquid coins.

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Mandate: Crypto · Benchmark: Bitcoin USD

Position limit 55% · Max drawdown 40% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

Track or modestly beat BTC via a diversified major-coin basket; volatility 40-70% (asset-class normal).

Risk tolerance

High. Crypto volatility managed via a cash buffer and large-cap focus; counts toward the 15% program crypto cap. Hard drawdown -40% raises the cash buffer and concentrates to BTC/ETH.

Time horizon

1-3 years.

Rebalancing

Monthly rebalance to target weights; maintain a cash buffer of at least 12%.

Liquidity

Top-liquidity coins only; spot holdings.

Benchmark policy

BTC-USD; success = tracking or modestly beating BTC with controlled concentration.

Review

Weekly volatility and concentration review; -30% soft / -40% hard drawdown triggers.

Asset allocation

  • Crypto (large-cap)88% (0-100%)
  • Cash12% (5-50%)

Target positions

BTC +55%ETH +25%SOL +8%

Permitted instruments

  • spot large-cap crypto (top-liquidity coins)
  • cash

Prohibited activities

  • leverage
  • staking
  • yield farming
  • wrapped tokens
  • illiquid/low-cap tokens
  • stablecoin credit exposure
  • single coin other than BTC above 25%

Risk limits

Concentration limit
55%
Max gross exposure
100%
Drawdown limit
40%

DBC Directional Alpha

Express the desk's highest-conviction directional ideas with a long bias, using modest shorts to fund longs and hedge. A concentrated, opportunistic complement to Core Equity.

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Mandate: Long bias · Benchmark: S&P 500

Position limit 12% · Max drawdown 25% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

SPY + 300-600 bps with higher dispersion; tracking error 6-12% vs SPY.

Risk tolerance

Moderate-high. Concentrated single names, nets long (target net 70-85%). Hard drawdown -25% de-grosses by >=1/3 and re-underwrites.

Time horizon

6-18 months per idea.

Rebalancing

Conviction-driven; re-sized on thesis change. Net exposure kept inside 60-100% (target 70-85%).

Liquidity

Liquid large/mid caps both legs; shorts only in easy-to-borrow names with a confirmed locate.

Benchmark policy

SPY total return; success = excess return net of the higher tracking error.

Review

Bi-weekly conviction and gross/net review; cover shorts on borrow deterioration or buy-in risk.

Asset allocation

  • US Equity (long)80% (60-100%)
  • Equity (short)10% (0-45%)

Target positions

NVDA +12%MSFT +11%AMZN +11%META +10%LLY +10%AVGO +9%NFLX +9%CRM +8%SPY -6%INTC -4%

Permitted instruments

  • US-listed common equity (long and short)
  • index ETF hedges

Prohibited activities

  • hard-to-borrow or special-rate shorts
  • leverage beyond 150% gross
  • options
  • names below $1B market cap

Risk limits

Concentration limit
12%
Max gross exposure
150%
Drawdown limit
25%

DBC Global Compass

Express top-down macro views across global equities, rates, commodities, FX and crypto via liquid ETFs and major coins - the program's diversifying macro engine.

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Mandate: Global macro · Benchmark: iShares Core Growth Allocation ETF

Position limit 15% · Max drawdown 20% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

AOR (global 60/40) + 200-400 bps as a diversifying return stream; target volatility 8-14%.

Risk tolerance

Moderate-high. Directional macro with strict per-theme sizing; non-ETF/coin position <=15%, single ETF <=20%, single coin <=10%, gross <=150%. Hard drawdown -20% de-grosses.

Time horizon

1-9 months per theme.

Rebalancing

Re-balanced on macro-regime change; shorts (if used) via liquid inverse ETFs only - disabled in the initial deployment.

Liquidity

Liquid ETFs and top-liquidity coins only.

Benchmark policy

AOR total return; success = excess return with diversification benefit to the program.

Review

Bi-weekly macro dashboard and scenario stress; -15% soft / -20% hard drawdown triggers.

Asset allocation

  • Equity ETF42% (0-90%)
  • Rates/Commodity/FX ETF32% (0-90%)
  • Crypto13% (0-15%)

Target positions

SPY +20%EFA +12%EEM +10%TLT +12%GLD +12%BTC +8%ETH +5%UUP +8%

Permitted instruments

  • liquid ETFs (equity, rates, commodity, FX)
  • major crypto (BTC, ETH)
  • inverse/short ETFs for hedging

Prohibited activities

  • single-name equity shorts
  • crypto above 15% of NAV
  • single ETF > 20%
  • single coin > 10%
  • gross > 150%

Risk limits

Concentration limit
15%
Max gross exposure
150%
Drawdown limit
20%
Max illiquid exposure
0%

DBC Neutral

Low-volatility, market-independent returns from paired longs and shorts at near-zero net market exposure. Framed honestly as low-gross educational pairs trading, not a full hedge-fund-style market-neutral book.

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Mandate: Market neutral · Benchmark: 1-3 Month Treasury Bill ETF

Position limit 5% · Max drawdown 10% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

BIL + 300-500 bps with target volatility under 6% and net beta to SPY approximately zero.

Risk tolerance

Low net-market, moderate idiosyncratic. Single position <=5%; gross <=60%. Hard drawdown -10% de-grosses.

Time horizon

3-9 months per pair.

Rebalancing

Weekly re-balance to neutral; re-match pair betas so net and portfolio beta stay in band.

Liquidity

Both legs liquid and borrowable; locate confirmed.

Benchmark policy

Benchmark BIL (cash); success = low-volatility absolute return uncorrelated to SPY.

Review

Weekly net/beta and pair-correlation review; portfolio beta finalized from measured pair betas at deployment.

Asset allocation

  • Equity (long)24% (0-30%)
  • Equity (short)24% (0-30%)

Target positions

JPM +5%CMA -5%COST +5%M -5%NVDA +5%INTC -5%MSFT +5%HPQ -5%PG +4%KHC -4%

Permitted instruments

  • US-listed common equity (paired long/short, borrowable, liquid)

Prohibited activities

  • net market exposure outside -10% to +10%
  • gross > 60%
  • single position > 5%
  • non-borrowable shorts

Risk limits

Concentration limit
5%
Max gross exposure
60%
Drawdown limit
10%

DBC Systematic

A rules-based multi-factor book (quality, value, momentum, low-vol) holding a broad, diversified basket sized by signal - the program's disciplined, repeatable systematic sleeve.

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Mandate: Quant systematic · Benchmark: S&P 500

Position limit 5% · Max drawdown 20% · Deployment target 50%

Last updated Jun 22, 2026

Full policy

Return objective

SPY + 150-300 bps via breadth; tracking error 2-5%.

Risk tolerance

Moderate. Diversified and factor-balanced; no single name above 5%; >=20 names. Hard drawdown -20% triggers model review.

Time horizon

Rolling, monthly rebalance to model weights.

Rebalancing

Monthly rebalance to composite factor-score weights (quality, value, momentum, low-vol), each capped at 5% and renormalized to ~96% net.

Liquidity

Large/mid-cap basket; all positions liquid.

Benchmark policy

SPY total return; success = excess return at low tracking error.

Review

Monthly factor-exposure and turnover report; -20% hard drawdown triggers a model (not discretionary) review.

Asset allocation

  • US Equity96% (60-100%)
  • Cash4% (0-40%)

Target positions

NVDA +5%MSFT +5%AAPL +4.7%AVGO +4.6%LLY +4.5%JPM +4.4%V +4.3%MA +4.2%COST +4.1%UNH +4%HD +3.9%ABBV +3.8%MRK +3.7%XOM +3.6%CVX +3.5%PG +3.4%KO +3.3%PEP +3.2%TXN +3.1%QCOM +3%CAT +3%DE +2.9%GE +3.6%ABT +3.5%BAC +3.4%

Permitted instruments

  • US-listed common equity (signal-weighted)
  • broad equity ETFs

Prohibited activities

  • discretionary override of model weights
  • single name > 5%
  • shorts (permitted by policy but disabled in initial deployment)

Risk limits

Concentration limit
5%
Max gross exposure
100%
Drawdown limit
20%

Low-volatility

Platform-owned demonstration fund. Runs Low-volatility — Baker, Bradley & Wurgler (2011), "Benchmarks as Limits to Arbitrage." Bets against the textbook risk-return tradeoff: the calmest stocks, not the wildest ones, have historically delivered the best risk-adjusted returns. Long-only, bottom quintile by trailing volatility, rebalanced monthly. Trades exclusively through the internal DBC engine on live market data; every fill is real engine mechanics against a synthetic demonstration book, not a real-money account.

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Mandate: Systematic · Benchmark: S&P 500

Position limit 30% · Max drawdown 30% · Deployment target 100%

Last updated Aug 8, 2026

Full policy

Return objective

Track the published Low-volatility factor's historical edge over SPY, for demonstration only.

Risk tolerance

Long-only, fully invested, equal-weighted across the current ranked holdings.

Time horizon

Rolling — re-ranked and rebalanced on the strategy's stated cadence indefinitely.

Rebalancing

Re-ranked and rebalanced monthly; targets are recomputed from the current universe each cycle, not held fixed.

Liquidity

Universe is limited to liquid US large/mid-cap common stocks.

Benchmark policy

Reviewed against SPY for demonstration context; not a promise of outperformance.

Review

Automated: the platform's cron lane re-ranks and rebalances on the stated cadence with no manual step.

Asset allocation

  • EQUITY100% (0-100%)

Target positions

MCD +7.142857%KO +7.142857%JNJ +7.142857%LIN +7.142857%PG +7.142857%COST +7.142857%TJX +7.142857%PEP +7.142857%BAC +7.142857%V +7.142857%JPM +7.142857%UNP +7.142857%MA +7.142857%MDT +7.142859%

Permitted instruments

  • EQUITY

Prohibited activities

  • live trading
  • real-money promotion
  • short selling
  • leverage

Risk limits

Concentration limit
30%
Max gross exposure
105%
Drawdown limit
30%

Momentum 12-1

Platform-owned demonstration fund. Runs Momentum 12-1 — Jegadeesh & Titman (1993), "Returns to Buying Winners and Selling Losers." Bets that stocks which have outperformed over the last year keep outperforming, and skips the most recent month to dodge short-term reversal. Long-only, top decile of the universe, rebalanced weekly. Trades exclusively through the internal DBC engine on live market data; every fill is real engine mechanics against a synthetic demonstration book, not a real-money account.

View fund page

Mandate: Systematic · Benchmark: S&P 500

Position limit 30% · Max drawdown 30% · Deployment target 100%

Last updated Aug 8, 2026

Full policy

Return objective

Track the published Momentum 12-1 factor's historical edge over SPY, for demonstration only.

Risk tolerance

Long-only, fully invested, equal-weighted across the current ranked holdings.

Time horizon

Rolling — re-ranked and rebalanced on the strategy's stated cadence indefinitely.

Rebalancing

Re-ranked and rebalanced weekly; targets are recomputed from the current universe each cycle, not held fixed.

Liquidity

Universe is limited to liquid US large/mid-cap common stocks.

Benchmark policy

Reviewed against SPY for demonstration context; not a promise of outperformance.

Review

Automated: the platform's cron lane re-ranks and rebalances on the stated cadence with no manual step.

Asset allocation

  • EQUITY100% (0-100%)

Target positions

AMAT +14.285714%AMD +14.285714%CAT +14.285714%CSCO +14.285714%LLY +14.285714%TGT +14.285714%GOOGL +14.285716%

Permitted instruments

  • EQUITY

Prohibited activities

  • live trading
  • real-money promotion
  • short selling
  • leverage

Risk limits

Concentration limit
30%
Max gross exposure
105%
Drawdown limit
30%

Quality tilt

Platform-owned demonstration fund. Runs Quality tilt — Asness, Frazzini & Pedersen (2019), "Quality Minus Junk." Bets that steadier, more consistent compounders outperform riskier ones over time — a price-behavior proxy for the paper's profitability, growth, and safety composite. Long-only, top quintile, rebalanced monthly. Trades exclusively through the internal DBC engine on live market data; every fill is real engine mechanics against a synthetic demonstration book, not a real-money account.

View fund page

Mandate: Systematic · Benchmark: S&P 500

Position limit 30% · Max drawdown 30% · Deployment target 100%

Last updated Aug 8, 2026

Full policy

Return objective

Track the published Quality tilt factor's historical edge over SPY, for demonstration only.

Risk tolerance

Long-only, fully invested, equal-weighted across the current ranked holdings.

Time horizon

Rolling — re-ranked and rebalanced on the strategy's stated cadence indefinitely.

Rebalancing

Re-ranked and rebalanced monthly; targets are recomputed from the current universe each cycle, not held fixed.

Liquidity

Universe is limited to liquid US large/mid-cap common stocks.

Benchmark policy

Reviewed against SPY for demonstration context; not a promise of outperformance.

Review

Automated: the platform's cron lane re-ranks and rebalances on the stated cadence with no manual step.

Asset allocation

  • EQUITY100% (0-100%)

Target positions

AMAT +7.142857%JNJ +7.142857%AMD +7.142857%MRK +7.142857%TGT +7.142857%CAT +7.142857%CSCO +7.142857%XOM +7.142857%MS +7.142857%BMY +7.142857%KO +7.142857%LLY +7.142857%GOOGL +7.142857%DE +7.142859%

Permitted instruments

  • EQUITY

Prohibited activities

  • live trading
  • real-money promotion
  • short selling
  • leverage

Risk limits

Concentration limit
30%
Max gross exposure
105%
Drawdown limit
30%