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Disclosure Data: Trade on the Filing Date, Not the Transaction Date

Public disclosures describe trades that already happened; a signal can start only when the filing becomes public.

3 min readResearch and simulation only
Disclosure dataEvent timingLook-ahead bias
The east front of the United States Capitol.
Photo (cropped and colour-graded): Martin Falbisoner · CC BY-SA 3.0 · source
In this note

Working definition

A reporting lag is the time between an event and the public record of it. For disclosure datasets, the transaction date describes what happened; the date the filing became public determines when anyone outside could act on it.

01

Two dates, one signal

Many disclosure regimes require a filing after a transaction rather than at the moment it occurs. Financial disclosure reports published by the Clerk of the U.S. House of Representatives, for example, include information about the source, type, amount or value of members' incomes, and they reach the public only once filed. The gap between an underlying trade and its public record can run from days to weeks.

A backtest keyed to transaction dates assumes the strategy knew about each trade when it happened. Keyed to the date each filing became public, the same dataset describes a strategy that could have been followed. The difference can be large for any signal whose information decays quickly.

02

Model the record as it appeared

Filings are amended, late filings appear, and some records arrive in batches. Each version should carry the time it became public. Datasets that report amounts as ranges should keep the range rather than a point estimate chosen later, and the matching of filer names to tickers should be reproducible from information available at the time.

An illustrative test might buy a stock in the session after a filing that discloses a purchase. The study can also show the same rule keyed to transaction dates, labelled as infeasible, so that the reader sees how much of the apparent edge depended on information nobody had yet. This is a hypothetical design, not a result from a Validraft client strategy.

  • Index every disclosure by the time it became public, and keep the transaction date as a separate field.
  • Keep amendments and late filings as new versions with their own publication times.
  • Preserve reported ranges and document any mapping from names to instruments.

03

Short histories call for modest claims

Many disclosure datasets are recent or have changed format over time. Few independent events, clustering in particular sectors, and changes in filing behavior limit how much a backtest can say. A report should give event counts after filtering, coverage by year, and results with and without the most concentrated periods.

The useful conclusion is often narrower than the headline: an effect that survives realistic filing dates, costs and timing is a research result worth monitoring, not yet a validated strategy.

Practical takeaways

  • Signals from disclosures can start only when the filing becomes public.
  • Show transaction-date results only as a labelled, infeasible comparison.
  • Version amendments and late filings with their own publication times.
  • Short, clustered histories support narrow claims rather than broad verdicts.

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