---
title: "Keep a selective-disclosure log for an issuer"
url: "https://ailawframework.com/practice/in-house-general-counsel/keep-the-continuous-disclosure-decision-log-for-a-developing-matter/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A40-D20261018-5-US"
practice_area: "In-House / General Counsel"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Keep a selective-disclosure log for an issuer

> Record, from the facts the lawyer enters, who outside the issuer received the information, when, whether the lawyer calls the disclosure intentional, and whether public disclosure has been noted.…

Canonical page: https://ailawframework.com/practice/in-house-general-counsel/keep-the-continuous-disclosure-decision-log-for-a-developing-matter/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [In-House / General Counsel](https://ailawframework.com/practice/in-house-general-counsel.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | Record, from the facts the lawyer enters, who outside the issuer received the information, when, whether the lawyer calls the disclosure intentional, and whether public disclosure has been noted. Do not decide that the information is material and do not decide that a disclosure is required. |
| What the lawyer must review | 17 C.F.R. § 243.100(a) provides that whenever an issuer, or a person acting on its behalf, discloses any material nonpublic information regarding that issuer or its securities to a person described in paragraph (b)(1), the issuer shall make public disclosure of that information as provided in § 243.101(e): simultaneously, if the disclosure is intentional, and promptly, if it is not. Paragraph (b)(1) covers specified outside persons, including brokers and dealers, certain investment advisers and institutional investment managers, certain investment companies, and a holder of the issuer's securities where it is reasonably foreseeable that the person will trade on the information. Paragraph (b)(2) states disclosures to which paragraph (a) does not apply, including a person who owes a duty of trust or confidence to the issuer, such as an attorney, investment banker, or accountant, and a person who expressly agrees to keep the information confidential. Section 243.101(e), which states how public disclosure is made, was not opened. The tool does not define promptly, does not decide materiality, and does not decide that the issuer is the kind of issuer the regulation covers. The lawyer makes those decisions. The log records what the lawyer enters. |
| Written for | United States |
| Applies to | [Keep the continuous-disclosure decision log for a developing matter](https://ailawframework.com/practice/in-house-general-counsel/keep-the-continuous-disclosure-decision-log-for-a-developing-matter.md) |

## Checking plan

- What the AI does: Record, from the facts the lawyer enters, who outside the issuer received the information, when, whether the lawyer calls the disclosure intentional, and whether public disclosure has been noted. Do not decide that the information is material and do not decide that a disclosure is required.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Do not treat a private company as an issuer under Regulation FD. The lawyer decides whether the regulation applies.
- Public-disclosure mechanics sit in 17 C.F.R. § 243.101(e), which was not opened. The log does not describe them.

## Sources

- [17 C.F.R. § 243.100 (Regulation FD, selective disclosure)](https://www.ecfr.gov/current/title-17/chapter-II/part-243/section-243.100) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Continuous disclosure decision log: facts before any announcement](https://ailawframework.com/precedents/in-house-general-counsel/continuous-disclosure-decision-log.md) | Checklist | Yellow | A log of information that may need disclosure, limited to what ASIC's handling-corporate-information page says.… |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*