What "notification" means
The notification date is a field on the form: "the month, day, and year
that you were notified of the transaction". The guide adds that "if you
executed the trade yourself, in most cases this will be the transaction
date". The gap opens when someone else trades on the member's behalf. Three
situations account for most of it.
- Managed accounts. An adviser with discretion over an
account can trade without asking. The member learns of the trade from a
confirmation or a statement, and the 30-day clock starts then. On the
filing, the account often appears on the "Subholding Of" line.
- Spouses and dependent children. The member reports
their trades too, but may hear about them late. The guide's spouse
example: a spouse buys on July 9 and mentions it on September 3. The
due date was August 23, so the report is already late when the member
first learns of the trade.
- Brokers executing orders. Even an order the member
placed can execute on a date the member only confirms later; the
guide's examples treat the broker's confirmation as the
notification.
The notification date is self-reported, and nothing on the form verifies
it. Read it as the filer's account of when they knew, which is what the
deadline turns on.
Weekends, holidays and extensions
PTR deadlines are strict in two ways that annual reports are not. The
Committee can grant extensions of up to 90 days for an annual Financial
Disclosure report, but "extensions for PTRs are not permitted under the STOCK
Act". And while an annual report's deadline moves to the next business day
when it falls on a weekend or holiday, a PTR's does not: it can still be
filed electronically that day, but a paper form must reach the Clerk, or be
postmarked, by the last business day before.
Late filings and the $200 fee
A report filed more than 30 days after its due date carries a filing fee
of $200 under
5
U.S.C. 13106(d), which the ethics committee "may waive ... in
extraordinary circumstances". Two details from the House guide change how to
read a late filing. First, there is a grace period: the fee
"is not assessed until the 31st day after the original due date", so a
report filed 50 days after the trade is late but fee-free, and one filed 80
days after it owes $200. In the spouse example above, the member is told to
file "immediately" and owes nothing if the report is in before September 22.
Second, repeat lateness costs more: "all late PTR submissions are subject to
a minimum fee of $200", and "multiple late PTR filings could result in
additional fees". The fee is paid to the U.S. Treasury and the report is
still published. Knowingly and willfully failing to file, or falsifying a
report, is a different matter:
section
13106(a) allows a civil penalty of up to $50,000, and the form itself
warns that 18 U.S.C. 1001 applies to false statements.
Why a trade disclosed weeks later is old news for price
Forty-five calendar days is roughly 31 trading days. In that time a stock
can report earnings or announce a deal, an index can rebalance, and the price
the member paid or received has moved, sometimes a lot. A Form 4, by
comparison, reaches EDGAR within two business days of the trade, and in our
deduplicated Form 4 corpus the median arrives two calendar days after the
earliest transaction it reports
(Form 4 by the numbers).
That is why a congressional disclosure and an insider filing should not be
read as the same kind of information even when they name the same stock: one
tells you what someone did this week, the other what someone's account did
last month, in a range. Read the
side-by-side
comparison before you line them up.
The lag also means a PTR cannot tell you what the trade was worth at the
time of reading. InsiderAlpha does not compute a return since the trade for
any congressional disclosure, because the filing gives no price and no share
count, and a range divided by a guessed price is not a number worth
printing.
Reading days to disclose and the late marker
Each trade on the Congress trades
page and in the tracker shows
the number of days from the transaction date to the filing date. Take
Filing
ID 20035590: a joint sale of Applied Materials dated 09/15/2026, notified
10/06/2026, and filed (digitally signed) 10/07/2026. That is 22 days from
trade to filing, inside both clocks, and the one-day gap between notification
and filing says the member reported it the day after learning of it. Read the
two dates together: a long gap between trade and notification points at a
managed account or a family member's trade; a long gap between notification
and filing points at the filer.
The late marker appears when the filing date is more than
45 days after the transaction date. That is the hard ceiling in the statute,
so a trade marked late was late whatever the notification date says. The
marker is deliberately narrow: a filing inside 45 days can still have missed
the 30-day clock if the member was notified early, and the tracker does not
try to judge that, because the notification date is self-reported. You can
check it yourself by comparing the notification and filing dates. In the
tracker, the member leaderboard counts each member's late filings and shows a
median lag, so repeat lateness is visible without opening every document.
One more thing to check before reading a long gap as a late original: the
filing status. When a report is amended, the tracker keeps
the newest copy of each trade as the primary record and shows its status as
Amended. The days shown are measured to that filing, so an amendment filed
months later can show a long gap even when the original report was on time.
The original is still on the Clerk's site under its own filing ID.
Recent House disclosures, with days to disclose → ·
The STOCK Act explained → ·
The Form 4 two-business-day rule →
This article is informational and is not investment advice.