Sep. 11, 2026
Max Well Apex LLC, NY, USA maxwellapexlab@proton.me September 11, 2026 Office of the Secretary U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549 Re: File No. 4-913, Roundtable on Preparations for 24-Hour Trading. Comment on disclosure-arrival timing as a market-structure variable Dear Ms. Countryman: Max Well Apex LLC is a New York company that builds data-integrity infrastructure for AI systems and trading models that consume SEC filings. We have submitted three comments this year on the point-in-time integrity of EDGAR structured data. This comment raises a distinct question that 24-hour trading brings to the surface on its own. The problem. As U.S. equity trading moves toward near-continuous operation, the interval between a filing's public availability and active trading narrows. EDGAR records an acceptance date and time for every submission, but the Commission's own EDGAR guidance states that "there is no timestamp to indicate when filing content is first available on sec.gov," and that filings "are often available on sec.gov within 1-3 minutes of the EDGAR system timestamp," a lag the Commission says it does not guarantee and cannot predict. For ordinary filings there is therefore no published, machine-readable, second-resolution record of first public availability against which overnight surveillance, trading systems, and AI models trained on filings can be audited, and no preserved record of what the public dissemination record itself looked like at each prior moment. The suggested items, tied to the roundtable's panels. 1. Panel One, Preparedness for a 24-Hour Market. Publish, for every filing, alongside the existing acceptance date and time, a first-public-availability timestamp at second resolution, with time zone stated, in a machine-readable index. This bears directly on the panel's closing price processes and investor protection practices. 2. Panel Two, Resiliency in a 24-Hour Market. Preserve an observable sequence of the dissemination record itself, a point-in-time view of what was public at any instant, so that market-data continuity and overnight surveillance can be reconstructed and audited after the fact, not only monitored in real time. 3. Panel Three, Expected Impacts and Consideration of Next Steps. Treat information-arrival timing as a market-structure variable in the Commission's analysis of overnight liquidity and fairness, alongside the venue and settlement variables already in scope. Evidence that arrival timing carries information, and that ignoring it can bias downstream analysis, comes from our public audit registry (github.com/MaxWellApexLab/pit-audit-registry). On an EDGAR as-filed fundamentals panel built from observed filing dates, an arrival-order screen flagged 7 of 14 standard signals across 28 of 84 signal-cycles, while return on assets stayed clean at 0 of 6. On FDA adverse-event data (AEMS, formerly FAERS), used as a non-financial control, the serious-event-share signal was flagged in 31 of 31 screened quarters, with mean correlation of positive 0.1987 against a noise floor of 0.0507. Shuffling the arrival order collapsed every reading to at most 0.0268, which isolates arrival order itself, not the content, as the source of the signal. A reference implementation, pit-release-gate, is published on PyPI under the MIT license. Related preprints are at doi:10.6084/m9.figshare.32952482, doi:10.6084/m9.figshare.33061955, and doi:10.6084/m9.figshare.33158615. None of these items requires a new disclosure obligation on issuers. They concern the Commission's publication infrastructure and the machine-readable record of when information becomes publicly available. Respectfully submitted, Kuan-Ta Wu Head of Engineer Max Well Apex LLC