Timestamp each investor statement against the audience that received it, watch for anything said to one room and not the market, and hold the corrective for a named disclosure officer.
A statement is drafted, and 17 CFR Part 243 governs who may hear it first.
02
A remark is intentional, and § 243.100(a)(1) wants the market told simultaneously.
Reason
03
A slip is unintentional, and § 243.100(a)(2) wants public disclosure promptly.
04
A senior official learns of that slip, and § 243.101 starts twenty-four hours.
05
A next NYSE open falls later, and § 243.101 makes that opening the deadline.
Decide
06
A listed recipient hears it, and § 243.100(b)(1)(i) to (iv) names the classes.
07
A results release goes out, and Form 8-K Item 2.02 leaves four business days.
Out
08
A non-GAAP measure appears, and Item 10(e)(1)(i) wants the reconciliation beside it.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
Both timings belong to the agent. Nothing under Regulation FD is signed, certified or attested; the disclosure officer who clears a statement is named by your own policy, not by the rule.
2Disclosure context assembledThe remark, the audience that heard it, the rule it answers to and the hour the clock started
3Audience evidence draftedThe remark, the recipients under it, the gaps and completeness
4Controls appliedRecipient checks, simultaneity checks, clock checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is cleared at any of them — the agent is assembling, and disclosure counsel enters at the completeness gate.
5DecisionSplits at the completeness gate
Evidence sufficient
Passes to the disclosure officer to clear.
Anything thin
Adds a disclosure counsel read first.
Disclosure counsel review
The remark is held with its audience, its gaps and the hour it went out.
Clear · Append evidence · Send for counsel read
Cleared — by the disclosure officer▼
6Statement and transcript records updatedOnly where write access and records policy allow it
7Outcome evaluatedAudience completeness, clock coverage, counsel corrections and what review found
Corrections
Each correction from review is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Deciding a fact is material and non-public.
Judging whether a selective remark was intentional.
Clearing any statement for release to the market.
Settling when the promptness clock has expired.
Automation boundaryAgent acts unaided
✓Hold each statement beside the audience that actually received it.
✓Start the clock at the hour a senior official spoke.
✓Flag a remark that reached one room and never reached the market.
✓Draft the corrective statement for its named signer.
Nothing is cleared and nothing goes out to the market unless a named person says so.
Judging whether Regulation FD was breached.
Telling an analyst that a remark was harmless.
Signing the Form 8-K that furnishes the results.
Changes to a transcript, a script or the record.
Example output
One investor statement, annotated
Our performance reporting agent drafts campaign reporting for an agency client; this page is about what the company may say to the market, and when.
Investor statement · single remarkIllustrative example
Statement
Recorded as
Audience
Evidence of record
Confidence
Held for
Corridor remark, § 243.100(a)(2)
Drawn from the notes each attendee kept
Margin remark
Conference notes, 3 August 2026
Held uncleared
The disclosure officer, by name
As receivedBuilt out of the conference notes and the call recording — nothing beyond those two is claimed.
What the record holdsConference notesAnalyst emailCall recording
Why no signature appears hereWhether the remark was material is a judgement Regulation FD leaves to people.
ActionClearAppend evidenceSend for counsel read
What the score decidesBelow the configured threshold a statement picks up a counsel read before clearance.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every statementFrom the audience it reached
03Evidence
Where the evidence is used
The § 302 and § 906 certifications belong to the principal executive and principal financial officers under Rule 13a-14, which permits no power of attorney; that is Finance work, claimed nowhere here.
01Approved path
The clock starts on a slip
Under § 243.101 promptness runs no later than twenty-four hours after a senior official learns, or the commencement of the next day's trading on the New York Stock Exchange, whichever is later.
02Human review
What was checked, and not found
The Form 8-K signature block was not obtained verbatim, so none of it is quoted; Rule 12b-11(d) confirms only that a duly authorized officer signs for the registrant, which attests authority rather than the accuracy of the figures. No penalty figure is published, because none was confirmed in primary text, and no amendment to Part 243 after 85 FR 33360 was located.
04Build an evidence trail
The statement, the audience it reached and the officer who cleared it stay on the record.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Integration availability depends on the client's existing systems and API access.
Agent controls
Six drums between the model and the officer
Six drums turning in sequence, the last the slowest. What survives the last is named in the map below.
L6 · Outermost — last line of defenceInward → L1 · closest to the model
L6Rollback / safe modeNarrow the agent to statement assembly when evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt and disclosure rules; the semiannual Form 10-S proposal, Release 33-11414, closed comments on 6 July 2026 and has no adopting release, so Rule 13a-13 still governs.Track
L4TraceabilityRecord each remark, the audience under it, the hour it went out and every read of the file.Record
L3Clearance gateHold the statement for the named disclosure officer; Part 243 requires no signature of any kind, so that hold is policy rather than law.Gate
L2Audience guardrailsTest each recipient against the classes at § 243.100(b)(1)(i) to (iv) and the carve-outs at paragraph (b)(2), which carry no rating-agency exception.Restrict
L1Confidence thresholdsRoute a thin statement to a counsel read; § 243.102 provides that an FD failure is not by itself a Rule 10b-5 violation.Require review
Model coreStatement assembled — the remark, its audience, the clock and completeness
L1 – L2Test whether a statement may stand
L3Hands the clearance to a named person
L4 – L5Keep the statement and the audience behind it
L6Holds the statement uncleared when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the statement record that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the statement the market reads
Depth of coverage ▼
E1Final-output evaluationDid the record show which audience actually heard it?
E2Step-level evaluationDid the agent read the right transcript, the right channel and the live calendar?
E3Tool evaluationDid it read and write the correct statement record and the correct event?
E4Confidence calibrationDo low-confidence statements actually attract more counsel corrections?
E5Slice evaluationHow does performance change across specific audience types?
E6Business outcomeHow many statements needed a correction before clearance?
Floor — what the market was told
Failure modes
Where each failure originates in the agent
Seven failure modes, each placed at the stage where it first bites.
Agent lifecycleDirection of processing →
01 · Retrieval1 mode
MH-03
Stale audience read
The distribution list is not the one now in use.
Stage gathersThe events, the rooms, the remarks and the times
02 · Reasoning2 modes
MH-04
Remark timed, not evidenced
A statement is timed with nothing behind it.
MH-06
Proposal read as adopted
A proposed rule is worked as though final.
Stage proposesThe statements, their audiences and completeness
03 · Tool / write2 modes
MH-02
Thin statement passed forward
A statement passes on with no counsel read.
MH-05
Wrong audience on the record
The remark is bound to the wrong room.
Stage writesOnly where write access and approval policy allow it
04 · Output1 mode
MH-01
Cleared, audience unrecorded
The record shows clearance but not who heard it first.
Stage returnsThe statement an officer clears and the market reads
05 · Change / Version1 mode
MH-07
Silent clock drift
The deadline shifts in a release, and the held record keeps the older one.
Stage tracksModel, prompt, timing rules and audience fields
Sev-1 · a statement cleared on no recordSev-2 · wrong audience reaches the recordSev-3 · source degrades, statement held
An audience-level simultaneity figure can read clean while one-to-one analyst meetings carry most of the rework. Nestack reports the correction rate by audience, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
One-to-one analyst meetings
7.8%
3.6×
Review
Investor conferences
5.6%
2.6×
Review
Earnings calls and webcasts
3.4%
1.6×
Watch
Results releases
1.9%
0.9×
Normal
Bar: correction-rate lift vs. results-release baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What a corridor answer costs
A cycle shuts when the selective remark is a regression case. That suite is what the next statement cleared is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on one-to-one meetings.
02Diagnose
The answer given at the edge of a conference, which the transcript never carried, is replayed until one cause is left standing.
03Improve
The change ships numbered, and the statements that forced it ride with it.
04Verify
Nothing releases while one touched statement case is still red.
05Learn
It is retained for good, and the clearance rules are amended in that same commit.
Learn → DetectThe return edge. The next statement is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, statement assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Disclosure-boundary and audience-mapping work.
02Transcript, wire and IR-desk sources.
03Statement-to-audience and clock-coverage mapping.
04Investor statement ingestion.
05Remark, audience and hour binding.
06Completeness scoring and review routing.
07Officer clearance workflow.
08Newsroom and transcript integration.
09Selectivity and timing cases.
10Guardrails and clearance controls.
11Statement-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne cycle, one marketProductionProduction disclosure workflowAdvancedMultiple markets / entities
Introduced at Pilot
Statement assembly to your calendar✓✓✓
Disclosure officer release✓✓✓
Disclosed-figure baseline✓✓✓
Introduced at Production
Reporting by audience—✓✓
Officer clearance workflow in your systems—✓✓
Approved write-back—✓✓
Transcript-and-filing integration—✓✓
Introduced at Advanced
Multi-market disclosure——✓
Cross-channel statement packs——✓
Large transcript estates——✓
Multi-channel timing controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, statement volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your reporting calendar and the audiences behind each event→Audience mapping and statement captureWeek 1
02Representative releases, scripts and call transcripts→Audience binding, clock logic and the statement baselineWeek 2
03Your standing disclosure policy and the officer it names→Audience mapping, clock binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Transcript, wire and IR-desk source assessment, then integration setupWeek 2
05Statements you would not want replayed→Timing cases and failure-mode testingWeek 4
06What no investor statement may promise→Completeness scoring, review routing, guardrails and release controlsWeek 3
07A named disclosure officer to clear what goes out→Officer clearance workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Every width answers to the work rather than the page, so a single week ends up holding two phases.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Disclosure workflow discovery, audience mapping and the automation boundaryW2Source integration and the investor-statement baselineW3Statement assembly, clock logic and release controlsW4Evaluation suite, selectivity cases and regression testingW5Transcript integration, pilot statements and targeted correctionsW6One reporting year run under the disclosure officer, then Agent Care handover
Reading the bandEach bar runs only as far as the work it names, and the fifth stretches to take two phases.
At the end of W6Validation closes on live statements, and Agent Care picks up the watch.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Strategy AI agent
Build an IR disclosure agent around the remark nobody put in the transcript.
Show us one statement and the room it was made in. The clock starts on what a senior official learned and when, not on anything anyone wrote down (§ 243.101). Under § 243.100(a)(1) an intentional selective disclosure has to reach the market at the same moment.
