SEC Disclosure Review
Catches real gaps staff attorneys did.
When a public company files a 10-K with the SEC, staff attorneys often respond with a comment letter pointing out disclosure gaps. This pack scores whether an AI reviewer catches the same gaps the real staff attorney caught — on real filings, against the real paired staff letters.
Highlights.
Every fixture grounded in a real (10-K, UPLOAD) pair from SEC EDGAR — no hand-typed content
Covers the disclosure topics SEC staff letters cite most often — risk factors, MD&A specificity, related-party transactions, non-GAAP reconciliations, climate (2024 rule), cyber-incident timing, and revenue recognition.
Deterministic check: agent's review must name the deficiency by label OR rule reference
29 real staff comment letters across 25 public-company registrants — tech, financials, industrials, pharma, energy, consumer
Bar-licensed securities-counsel sign-off pending (Phase L-5)
Vertical harnesses
are co-built.
Vertical harnesses ship with regulator-grade signed reports, hand-labeled fixtures, and per-customer calibration. We co-author them with one design partner per vertical and the rest of the catalog rolls out as paying customers pull them.
Example checks.
Catches an MD&A quantification deficiency
Misses a deficiency the staff letter raised
Judging criteria.
What a pass means
A pass means the agent named at least 80% of the deficiencies the paired staff letter raised — either by describing the issue (e.g. "generic cybersecurity risk factor") or by citing the rule (e.g. "Item 105 Reg S-K"). Adjustable passing score.
Data sources
- SEC EDGAR
Source of every filing and every paired staff letter in this pack. Federal-government works, public domain.
- Regulation S-K (17 CFR Part 229)
The rule framework staff cite in letters — Items 105, 303, 404, 10(e), 1500-series. Pack deficiencies point back to these items.
