Recommendation Disclosure

Last updated: Sep 10, 2026

Some of the content on this site — a published idea that names an instrument and suggests buying or selling it — may qualify as an investment recommendation under Article 20 of Regulation (EU) No 596/2014 (the Market Abuse Regulation) and Commission Delegated Regulation (EU) 2016/958. This page contains the disclosures that regime requires, and applies to every idea we publish.

1. Who produces the recommendations

Berto Production (Andrea Bertolotti), NIF Y-4514/312-R, Alicante, Spain, info@cadencesignals.com.

Every recommendation on this site is produced by Andrea Bertolotti, owner and editorial manager, who is the natural person responsible for it within the meaning of Article 2(1)(a) of Commission Delegated Regulation (EU) 2016/958.

We are not an investment firm or a credit institution within the meaning of MiFID II, and we are not authorised or supervised by the CNMV, CONSOB, the FCA or any other competent authority.

The category we fall into, stated plainly

For the purposes of Regulation (EU) 596/2014 and Delegated Regulation (EU) 2016/958 we operate as an expert within the meaning of Article 1(a) of that Delegated Regulation: we propose investment decisions repeatedly, and we present them in a way that could reasonably lead you to believe we have financial expertise. We say this openly because it decides which rules apply, and getting it wrong in our own favour would be the first thing a supervisor looked at.

The consequence is that both sets of obligations bind us: the general ones in Articles 2, 3 and 5 (identity, objective presentation, conflicts of interest) and the additional ones in Articles 4 and 6, which apply to experts and to those who produce recommendations professionally. Those additional requirements — the basis and methodology, the sensitivity of the assumptions, the date and time of the prices quoted, the planned frequency of updates, how a recommendation differs from the previous one on the same instrument, and the register of the past 12 months — are discharged in the sections below and inside each published idea.

A disclaimer alone would not change any of this. As the CNMV puts it in its finfluencer guidance, posting "this is not investment advice" does not protect you and does not remove the duty to comply. The protection comes from doing the things on this page, not from saying a sentence.

2. How the recommendations are produced

Each idea comes out of a scheduled market review run three times a day. The review is carried out with the assistance of an artificial intelligence system, working from publicly available market data: price history, technical levels, volatility measures and the published macroeconomic calendar. No non-public information is used, and no third party pays for or influences the content of an idea.

The full methodology, including the checklist an idea has to clear before it is published, is set out on the Method page. The model that generated each idea is named on the idea itself.

Sources

Prices, price history and volatility are taken from Yahoo Finance public quote and history pages — index futures (ES=F, NQ=F, GC=F) for the live price, the cash index series for the moving average and the ATR, and the spot pages for FX. The volatility regime filter reads the CBOE VIX quote from the same source. The macroeconomic calendar comes from published central-bank and statistical-office release schedules.

These are ordinary commercial and public sources. We do not verify them independently, they can be delayed or wrong, and the price your broker shows you will not be identical to ours. Where a price cannot be retrieved, the instrument is dropped from that review and we say so rather than estimate a level. We use no proprietary data and no non-public information.

Sensitivity of the assumptions

Every idea rests on three assumptions: that the structural level identified keeps being respected by the market; that volatility stays in the regime observed when we published; and that no uncalendared macroeconomic event lands inside the horizon.

If the first fails, the idea closes at the stop, for a loss of one unit of risk (−1R).
If volatility rises above the regime we observed, the realised loss can exceed −1R: a gap opening or a widening spread takes you out at a worse price than the stop.
If the horizon runs out with no level touched, the outcome is indeterminate and we record it at the market price.
If the direction is simply wrong, the whole declared risk is lost.

There is no configuration of these assumptions in which the maximum loss is structurally smaller than the risk declared on the idea. That is the honest answer, and it is why the risk is stated as a percentage before anything else.

3. What the recommendation terms mean

Term	Meaning
LONG	The idea anticipates a rise in the instrument's price from the entry level.
SHORT	The idea anticipates a fall in the instrument's price from the entry level.
Entry	The price level at which the idea is considered to begin. It is a reference level, not an instruction.
Stop loss	The level at which the idea is treated as wrong and is closed in the track record.
Target 1 / Target 2	The levels at which the idea is treated as having worked.
Risk	The share of a notional account, expressed as a percentage, that the simulated position risks between entry and stop. It is never an amount in currency.
R	The result expressed in multiples of the initial risk. +2R means the idea returned twice what it risked.
Conviction	An internal 1-to-5 score of how well the setup matched the checklist. It is not a probability.
Horizon	Intraday (hours) or swing (days). An idea that has not resolved by its expiry is closed at the market price and recorded as expired.

Ideas are not ratings on an issuer: we publish no judgement or valuation on a listed company, and we do not use a "buy / hold / sell" scale. Target 1 and Target 2 are price targets on the instrument, within the meaning of Article 3(1)(d) of Delegated Regulation (EU) 2016/958, and they are forecasts, not facts. The entry, the stop and the recorded prices are market data; the rationale, the method note and both targets are opinion and estimate. Where the two appear side by side on an idea, that is the line between them.

4. Record of past recommendations

Every idea we have published — including the ones that lost money and the ones that were cancelled — is listed in the register of the last 12 months, drawn up under Article 4(1)(i) of Delegated Regulation (EU) 2016/958. For each recommendation it gives the date and time of first dissemination with the time zone, who produced it, the instrument, the direction, the market price at that moment, both price targets, how long it was valid for and how it ended. The same page also carries the profit-and-loss view, with the result in R and as a percentage of equity. Records stay online for at least twelve months from publication.

Published ideas are never edited or deleted after the fact. Each one carries an append-only event log (created, published, closed) that is visible on the idea's own page.

5. Conflicts of interest

As at the date of this page:

Berto Production is not remunerated by any broker, exchange, issuer, fund or market maker in connection with the content published on this site.
We run no affiliate or introducing-broker arrangements, and we receive no payment, rebate or commission based on your trading volume, your losses, or on you opening an account anywhere.
We hold no position in the instruments covered, other than positions that may be taken in a personal capacity by Andrea Bertolotti. Where such a personal position exists in an instrument at the moment an idea on that instrument is published, it is disclosed in the body of the idea itself.
No person outside Berto Production sees an idea before it is published to all users at once.
During the beta the service is free of charge. If paid plans are introduced, subscription revenue will be the only source of income connected with this content, and this page will be updated before any such change takes effect.

If any of these facts changes, this page is updated and the change is noted in the newsletter.

6. Distribution and fair presentation

All registered users receive the same idea, with the same levels, at the same time. There is no premium tier that receives ideas earlier, and no idea is shared privately in advance. Facts are distinguished from interpretation in every idea: the levels and the market data are factual, the rationale is an opinion.

7. This is still not advice

Meeting these transparency requirements does not turn our content into investment advice, and it does not make it suitable for you. Please read the Risk Warning in full.

Contact

Berto Production — Andrea Bertolotti
NIF Y-4514/312-R
Alicante, Spain
info@cadencesignals.com