Build the trading-halt request record from the awareness timeline
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- The tool lists the time the company became aware, whether that time is between 7:00 a.m. and 4:00 p.m. Eastern Time, whether the window is 7:00 a.m. to 9:25 a.m. or 9:25 a.m. to 4:00 p.m., the Regulation FD method, and how the Exchange can locate the announcement. It does not write the halt request or the announcement.
- What the lawyer must review
- The NYSE 2026 Annual Guidance Letter and Regulation FD, 17 CFR § 243.100. The letter is dated 27 January 2026. It says a listed company calls the Exchange's Market Watch group at 212-656-5414 or 877-699-2578 when it intends to release material news between 7:00 a.m. ET and 4:00 p.m. ET. The call is 10 minutes before dissemination of news of a material nature, including any dividend or stock distribution, or promptly upon becoming aware of a material event beyond the company's control, and the company also takes steps to release the news promptly. The caller must be knowledgeable about the details. The company provides a copy of the announcement, the Regulation FD-compliant method, and how the Exchange can locate the news, through Listing Manager or nysealert@nyse.com. Between 7:00 a.m. and 9:25 a.m. ET, the letter says the Exchange will implement a news-pending trading halt only at the request of the company. Between 9:25 a.m. and 4:00 p.m. ET, the letter says it is the Exchange's practice to institute a trading halt pending dissemination if it believes the news is material and the company has not yet disclosed it in compliance with the Timely Alert policy. Outside 7:00 a.m. to 4:00 p.m. ET, the letter says companies are generally not required to call in advance, and they still provide a copy once the news is disclosed. Notice of a dividend or stock distribution is still required at least 10 minutes before any public announcement, including outside trading hours. The letter says listed companies are prohibited from publishing material news after the official closing time until the earlier of 4:05 p.m. ET or publication of the official closing price, citing Section 202.06. Regulation FD § 243.100(a) requires public disclosure, as provided in § 243.101(e), simultaneously in the case of an intentional disclosure and promptly in the case of a non-intentional disclosure, when material nonpublic information is disclosed to a person described in paragraph (b)(1). The lawyer writes the halt request and any public announcement.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Limit any support to organising, indexing or comparing the source material. The tool writes nothing that goes into the document. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Review operative clauses in the complete document, including definitions, cross-references, schedules and inconsistencies with the instructions.
- Verify dates, people and sequence against contemporaneous records. Preserve uncertainty and identify gaps or conflicting accounts.
- 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.