Michael T. McCaul × LMRK

This August 22, 2019 sell of approximately $1,001 in Landmark Infrastructure Partners was filed on October 15, 2019, a delay of 54 days. That exceeds both Kapitol.ai's 30-day internal flag threshold and the STOCK Act's 45-day statutory deadline. The trade itself is minimal in dollar terms, sitting at just 7 percent of the congressional median trade size. No other members traded LMRK in the surrounding two-week window, so there is no coordinated cluster signal. The late disclosure is the primary flag here. Viewed in isolation, a single small sell carries limited analytical weight, but this trade is part of a broader pattern across 98 total disclosed transactions in LMRK, several of which also carry late disclosure flags. The recurring tardiness across such a high volume of minimum-threshold trades warrants attention as an administrative pattern, regardless of the modest size of any individual transaction.

This August 23, 2019 sell, filed the same day as several other LMRK transactions on October 15, 2019, was disclosed 53 days after execution. That delay crosses the STOCK Act's 45-day statutory deadline. The trade is at the minimum reportable size of approximately $1,001, which is 7 percent of the congressional median. The simultaneous batch filing of multiple August and September 2019 LMRK trades on a single October date suggests that these small sells were not being individually tracked and reported as they occurred, but rather bundled and submitted together well past the required window. No peer clustering was detected for this trade. While the financial exposure is negligible at this size, the repeated pattern of bundled late filings across scores of minimum-threshold transactions is the substantive signal this record contributes to, when viewed alongside the full 98-trade disclosure history.

The August 26, 2019 sell of approximately $1,001 in Landmark Infrastructure Partners was reported on October 15, 2019, a 50-day delay that surpasses the STOCK Act's 45-day statutory filing deadline. Like the trades on August 22 and 23, this transaction was bundled into the same October 15 batch filing, indicating that multiple individual sells executed over several days were not individually disclosed within the required window. The trade itself is at the floor of reportable size and carries no unusual-size or cluster signal. The structural concern is the batch-disclosure approach: three sells in four trading days all filed simultaneously, each past the statutory deadline. Across the 98 total LMRK trades in the disclosed record, this behaviour appears to be part of a consistent administrative practice rather than an isolated oversight.

This December 12, 2019 sell in Landmark Infrastructure Partners was filed on January 29, 2020, a gap of 48 days. That delay pushes past the STOCK Act's 45-day statutory deadline, making this one of several trades in this dataset that crossed the legal filing window rather than merely triggering Kapitol.ai's internal 30-day flag. The trade is again at the minimum reportable size of $1,001, roughly 7 percent of the congressional median. No peer clustering is present. Coming several months after the August 2019 batch of late-filed sells, this December trade shows the same administrative pattern recurring in a new quarter: a single minimum-threshold sell reported beyond the statutory window. Across 98 total LMRK disclosures, this is consistent with a systemic, rather than situational, reporting lag for this particular holding.

The March 6, 2020 sell of approximately $1,001 in Landmark Infrastructure Partners was disclosed on May 6, 2020, a delay of 61 days. This is among the longest delays in the subset under review and substantially exceeds the STOCK Act's 45-day statutory filing deadline. The trade falls in early March 2020, a period of significant market volatility. Several LMRK sells followed in rapid succession over the subsequent two weeks, all filed on the same May 6, 2020 date in what appears to be another batch disclosure. The trade itself is at the minimum reportable threshold and carries no unusual-size or cluster signal. The 61-day delay, combined with the apparent bundling of multiple March 2020 sells into a single late filing, continues the administrative pattern visible across this politician's full 98-trade LMRK disclosure history.

This March 9, 2020 sell of approximately $1,001 in Landmark Infrastructure Partners was reported on May 6, 2020, a 58-day delay that crosses the STOCK Act's 45-day statutory deadline. The trade is three days after the March 6 sell (trade 49173) and was filed on the same batch date of May 6, 2020. The March 2020 window was a period of broad equity market stress, and multiple minimum-threshold LMRK sells were executed across several consecutive trading days. None of these sells were reported individually within the statutory window; all were grouped into a single late disclosure. The trade carries no unusual-size or clustering signal. As one of at least six March 2020 LMRK sells in this subset, all filed late and all at the minimum reportable size, this record reinforces the systemic disclosure lag pattern that runs throughout the 98-trade LMRK history.

The March 12, 2020 sell of approximately $1,001 in Landmark Infrastructure Partners was disclosed on May 6, 2020, a delay of 55 days, again past the STOCK Act's 45-day statutory deadline. This is the third sell in a sequence of minimum-threshold LMRK transactions executed between March 6 and March 17, 2020, all batched into the same late filing date. The period in which this trade was executed coincided with sharp broad-market declines, though no committee overlap or peer-cluster signals are present to suggest an information-advantage dimension to the timing. The financial exposure remains minimal at $1,001. The accumulating record of March 2020 sells, each at the minimum reportable floor and each filed past the statutory deadline, strengthens the case that this is a consistent administrative approach rather than ad hoc reporting, a pattern reflected across all 98 LMRK disclosures.

This March 13, 2020 sell of approximately $1,001 in Landmark Infrastructure Partners was filed May 6, 2020, representing a 54-day disclosure delay that exceeds the STOCK Act's 45-day statutory limit. It is the fourth in a consecutive-day sequence of minimum-threshold LMRK sells executed during a volatile market period in mid-March 2020. All trades in this sequence were disclosed together in a single batch filing, none individually reported within the required window. The trade size is negligible relative to congressional norms, at roughly 7 percent of the median. No peer-cluster or committee-overlap signals are present. The consistent pattern across this batch, and across the broader 98-trade LMRK record, indicates a recurring practice of grouping multiple small sells into periodic late omnibus disclosures rather than filing each transaction promptly as required.

The March 16, 2020 sell of approximately $1,001 in Landmark Infrastructure Partners was disclosed on May 6, 2020, a delay of 51 days, past the STOCK Act's 45-day statutory deadline. This is the fifth sell in the March 2020 sequence visible in this dataset, all at the minimum reportable threshold and all filed in the same batch. March 16, 2020 fell on a Monday following a weekend of significant policy developments related to the pandemic-era economic downturn. No committee-overlap or peer-cluster signals are present, and the trade size carries no unusual-size flag. The primary signal for this trade remains late disclosure. Across the full 98-trade LMRK record, the repeated combination of minimum-size trades and late batch filings is a consistent pattern, with multiple instances where statutory deadlines were not met.

This March 17, 2020 sell of approximately $1,001 in Landmark Infrastructure Partners was the last in the March 2020 batch visible in this dataset, filed on May 6, 2020 after a 50-day delay that exceeds the STOCK Act's 45-day statutory deadline. Six consecutive sells across March 6 through March 17, each at the minimum reportable size of $1,001, were all batched into a single late filing. No committee-overlap or peer-cluster signals are present, and the individual trade size is negligible. Viewed in the context of the full 98-trade LMRK disclosure record for Rep. McCaul, the pattern is one of high-frequency minimum-threshold sells combined with periodic, late batch filings. Multiple trades across multiple quarters in this record crossed the statutory 45-day deadline, presenting a systemic disclosure-timing concern that is distinct from any question of trade size or informational advantage.