---
title: "Check a draft periodic report against the officer-certification topics"
url: "https://ailawframework.com/practice/in-house-general-counsel/prepare-the-corporate-governance-statement-against-the-recommendations/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A40-D20261018-7-US"
practice_area: "In-House / General Counsel"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Check a draft periodic report against the officer-certification topics

> Against the draft annual or quarterly report the lawyer supplies, note whether the draft contains a sentence on each topic in 15 U.S.C. 7241(a) that the lawyer marks.…

Canonical page: https://ailawframework.com/practice/in-house-general-counsel/prepare-the-corporate-governance-statement-against-the-recommendations/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 | Yellow: Lawyer and AI draft together |
| How AI is used | Against the draft annual or quarterly report the lawyer supplies, note whether the draft contains a sentence on each topic in 15 U.S.C. 7241(a) that the lawyer marks. Do not write the certification and do not sign the report. |
| What the lawyer must review | 15 U.S.C. 7241(a) requires the Commission, by rule, to require that for each company filing periodic reports under section 78m(a) or 78o(d), the principal executive officer or officers and the principal financial officer or officers, or persons performing similar functions, certify in each annual or quarterly report that the signing officer has reviewed the report, that based on the officer's knowledge the report is not materially untrue or misleading, that the financial statements fairly present the financial condition and results of operations in all material respects, and the further internal-control matters stated in paragraphs (a)(4) through (a)(6). The statute applies to companies that file those periodic reports. It is not a statement of governance recommendations. ABA Formal Opinion 512 (29 July 2024) leaves the lawyer responsible for text produced with a generative tool. The officers sign. The tool does not. |
| Written for | United States |
| Applies to | [Prepare the corporate governance statement against the recommendations](https://ailawframework.com/practice/in-house-general-counsel/prepare-the-corporate-governance-statement-against-the-recommendations.md) |

## Checking plan

- What the AI does: Against the draft annual or quarterly report the lawyer supplies, note whether the draft contains a sentence on each topic in 15 U.S.C. 7241(a) that the lawyer marks. Do not write the certification and do not sign the report.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A private company that does not file reports under section 78m(a) or 78o(d) is not brought into section 7241 by this check.
- Exchange listing manuals were not opened. The check does not score the company against listing recommendations.

## Sources

- [15 U.S.C. 7241, Corporate responsibility for financial reports](https://www.law.cornell.edu/uscode/text/15/7241) (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)

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