Compare a proposed comment on a trading move with information already public
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Set the proposed sentence beside the page of a filed report, prospectus, or other document in the file that already states the same fact, and mark a proposed sentence with no such page. Write no statement for release and no script for an analyst call.
- What the lawyer must review
- You decide whether anything is said. Rule 10b-5 (17 CFR § 240.10b-5) makes it unlawful for any person, directly or indirectly, by use of any means or instrumentality of interstate commerce, or of the mails, or of any facility of any national securities exchange, in connection with the purchase or sale of any security, to employ any device, scheme, or artifice to defraud, to make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made not misleading, or to engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person. A price or volume move is not, in that rule, itself a statement. Regulation FD (17 CFR § 243.100(a)) requires public disclosure, as provided in § 243.101(e), when material nonpublic information is disclosed to a person described in paragraph (b)(1). The method of that public disclosure is in § 243.101(e), which was not opened, and no Form 8-K filing period was taken from the form. You decide whether a proposed sentence is an untrue statement or a misleading omission, and whether a selective disclosure has been made. ABA Formal Opinion 512 requires independent verification before generated output is relied on.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Do not begin AI assistance until the responsible lawyer has defined and confirmed its permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Check the current court or regulator requirements, prescribed form and attachments for the intended document and filing.
- Review the original source set for relevant material absent from the output, including contrary evidence, qualifications and remaining gaps.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.