# Tensorust LLC: MNPI policy and memo

Updated 2026-11-06. Online: https://shop.tensorust.com/funds/mnpi

How Tensorust keeps material non-public information out of its datasets. Applies to Contractor Credit, Private Credit Marks and every other Tensorust dataset sold to investment managers.

## 1. Every input is public record

Each field in the products comes from a filing or government record that is public when we collect it: SEC EDGAR filings and the SEC BDC data sets, USAspending.gov, DOL Form 5500 data sets, the Lobbying Disclosure Act API, FEC bulk files, the OFAC Sanctions List Service, the FCC Universal Licensing System and the FAA aircraft registry.

We collect only from official downloads and APIs that anyone can use without an account or a confidentiality undertaking. Each record keeps its source and, for lender marks, the filing date it became public.

## 2. What we never use

No information from employees, officers, directors or insiders of any issuer, borrower, lender, fund or contractor.

No data received under an NDA or other confidentiality obligation, and no data-sharing agreements with issuers or lenders.

No expert-network calls, channel checks, surveys of company staff, or paid access to non-public company information.

No information obtained by breaching a website's terms, logging in as someone else, bypassing access controls or CAPTCHAs, or exploiting misconfigured systems.

No information from government officials that is not itself published.

## 3. Our value is the join, not access

What Tensorust adds is work on public information. We resolve lender holdco names to operating companies, join them to federal records, and compare lenders. We are also fast: we pull 10-Qs from EDGAR the day they post, and we publish nothing before the underlying filing is public.

Being earlier or more organized than other users of public records does not make the information non-public.

## 4. If non-public information ever reaches us

Tensorust talks to companies and agencies in the ordinary course of selling its products, and a reply could contain non-public information. Any information we receive that is not public record is never added to a dataset, a model or a page.

It is kept out of the data pipeline. If we believe something received could be MNPI about an issuer in our data, we stop using that issuer's records until the information is public, and we tell licensees which issuer is affected without passing on the information.

## 5. We do not trade

Tensorust LLC holds no positions in securities, loans or derivatives and does not trade.

Restricted-list rule: anyone who works on Tensorust datasets, including the founder, may not trade securities of a BDC or of an issuer in a dataset they are building or delivering.

## 6. Equal access and no issuer influence

Each refresh reaches every licensee at the same time. No client is given a filing or a result earlier than another.

No issuer, lender or contractor pays to be included, excluded or described differently.

## 7. Records

For any delivered value, we can show the source record, its public URL and the date it was collected or filed. Clients may audit this on request.

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Tensorust LLC, 404 Read Ave, Tuckahoe, NY 10707. Questions: Matthew Busel, Founder, mattbusel@tensorust.com. This memo states Tensorust's own policy. It has not been reviewed by outside counsel and is not legal advice.
