Pistachio
Back to marketplace
LegalEnterpriseLegal

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)

Enterprise harness

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.

Examples

Example checks.

Check 01Deterministic

Catches an MD&A quantification deficiency

Input
Review this Oracle 10-K excerpt. Flag every deficiency a staff attorney would raise.
Expected behavior
Names the missing quantified MD&A discussion of cloud-migration revenue and the unquantified MD&A drivers; cites Item 303 Reg S-K. Matches both deficiencies the paired SEC UPLOAD letter raised.
Check 02Deterministic

Misses a deficiency the staff letter raised

Input
Review this Oracle 10-K excerpt. Flag every deficiency a staff attorney would raise.
Expected behavior
Agent offers generic disclosure commentary but does not name the MD&A quantification gap or Item 303. Fails recall against the paired staff letter.
Grading

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.