For NYSE-listed companies
Know what will draw a comment letter before you file.
Larger issuers get the closest reading: from SEC staff, from plaintiffs and from activists who compare every filing with the last one. Finiti form-checks your 10-K, 10-Q and proxy against Regulation S-K, current C&DIs and comment-letter patterns, and checks them against what you have already said in public.
What Finiti checks
The review your team runs by hand, cited to page and section.
Form check against the rules
Every item of the form checked against Regulation S-K, Regulation S-X and current staff guidance. Each finding cites the rule, page and section behind it.
Current C&DIs
Compliance and Disclosure Interpretations are refreshed and mapped to each disclosure item, so a position the staff has already published does not come back as a comment.
Comment-letter patterns
Language that matches what staff have recently commented on, such as non-GAAP measures, MD&A and segment reporting, is flagged while the filing is still private and fixable.
Risk factors that have gone stale
Hypothetical risks that have already happened, risks your peers have added or dropped this year, and the Item 105 summary when the section runs past 15 pages.
Consistency with what you said in public
Your 10-K checked against your last earnings call, investor presentation and press releases, so pricing, guidance and segment language say the same thing everywhere.
Proxy disclosure against peers
Executive compensation, clawback and governance disclosure compared paragraph by paragraph with your peer set, labelled standard, thin, inconsistent or novel.
For the people on the filing
In-house and outside counsel, on one record.
01
For the general counsel
A record of what was checked, against which source and which version, before you sign off. Judgment calls stay with your team.
02
For the disclosure committee
One flagged issue list instead of rounds of comments across email threads, with every change traced to its source document.
03
For outside counsel
The form check that takes an associate about five hours a filing, by one associate’s estimate, done before the draft reaches you. Your hours go to the questions that need a lawyer.
“I like the comparison. It keeps your company static and then you can scroll to the right and look at where the other ones are.”
Further reading