Transaction date vs. disclosure date

Two dates matter when reading a public trade record: the date the transaction occurred and the date the report became public. Confusing them can make an old trade look new.

Transaction date

This is when the purchase, sale, or exchange happened. Market conditions and the security's price on that date are the most relevant context for understanding the disclosed action.

Disclosure or filing date

This is when the report was submitted or published. Because the rules allow time for notice and filing, the public may see the record days or weeks after the transaction.

Why the gap matters

If a stock rises sharply between the transaction and filing dates, buying after the disclosure can produce a very different entry point. The official's portfolio may also have changed again before the public sees the first report.

A better reading habit

1. Start with the transaction date.
2. Compare it with the filing date.
3. Review the amount range and owner field.
4. Open the original filing.
5. Check current market conditions independently.

Official source: House Committee on Ethics—Financial Disclosure