Michael T. McCaul × LRLSQ

This December 6, 2019 sell of approximately $1,001 in LRLSQ was not disclosed until January 29, 2020, a delay of 54 days. That delay exceeds both Kapitol.ai's internal 30-day flag threshold and the STOCK Act's 45-day statutory filing deadline. The trade itself is small, sitting at just 0.07x the median transaction size in this dataset, suggesting it may be part of a systematic liquidation strategy rather than a single opportunistic move. Viewed in the broader context of 89 total disclosed trades for McCaul in this ticker, the batching of this disclosure alongside numerous other trades on the same filing date raises a structural question about whether disclosure was being aggregated rather than filed on a rolling basis. No peer cluster was observed around this date, and committee overlap cannot be established without reliable assignment data.

This December 8, 2019 sell of approximately $1,001 in LRLSQ carries a 52-day disclosure delay, clearing both the 30-day internal flag and the STOCK Act's 45-day statutory deadline. Like the adjacent trades in this dataset, it was grouped into a single January 29, 2020 filing alongside what appears to be a cluster of December 2019 transactions. The minimum-threshold trade size of $1,001 is consistent with the broader pattern across McCaul's 89 total disclosures in this ticker, suggesting a programmatic or managed exit from the position rather than discrete decision-making. No other members reported the same ticker within the 14-day window, limiting cluster inference. The primary flag here remains the statutory-level disclosure delay, which is factual and documentable from public disclosure data.

The December 9, 2019 sell of approximately $1,001 in LRLSQ was disclosed on January 29, 2020, producing a 51-day delay that exceeds the STOCK Act's 45-day statutory deadline. This trade falls within the same dense December 2019 selling sequence visible across McCaul's disclosed record for this ticker. The $1,001 figure represents the minimum reportable bracket, consistent with every other trade in this sample. When considered alongside 89 total disclosures in LRLSQ, the pattern suggests a prolonged, incremental divestiture of what may have been a substantial legacy position in the bankrupt retail entity. All trades in this sequence were batched into a single filing date rather than disclosed individually as executed, which is the core structural concern the late-disclosure signal captures.

This December 10, 2019 sell of approximately $1,001 in LRLSQ was filed on January 29, 2020, recording a 50-day delay that exceeds the STOCK Act's 45-day statutory deadline. The trade is unremarkable in size, registering at 0.07x the dataset median, and no peer cluster was observed in the surrounding two-week period. The significance of this individual trade is best understood in the aggregate: across McCaul's 89 total LRLSQ disclosures, December 2019 appears to represent a period of concentrated selling activity, all eventually batched into a single filing. Whether that batching reflects administrative consolidation or a lapse in timely disclosure process is unclear from public records alone, but the statutory-level delay is a matter of documented fact.

The December 11, 2019 sell of approximately $1,001 in LRLSQ was batched into the January 29, 2020 filing, resulting in a 49-day disclosure delay that crosses the STOCK Act's 45-day statutory threshold. This is one of several consecutive daily sells in the second week of December 2019, each at the minimum reportable value of $1,001. The repetitive cadence of these trades at identical dollar thresholds across consecutive trading days is consistent with an automated or broker-managed liquidation program. The absence of any peer-member activity around this date means no coordinated trading inference applies. The late-disclosure signal remains the primary flag, and its recurrence across multiple trades in this batch compounds the overall disclosure picture when viewed alongside McCaul's 89 total LRLSQ filings.

This December 12, 2019 sell of approximately $1,001 in LRLSQ records a 48-day filing delay, exceeding the STOCK Act's 45-day statutory deadline. It sits within the densest portion of the December 2019 selling sequence visible in this dataset. Each of the trades from December 6 through December 13 in this sample carries a statutory-level delay, suggesting that the batched January 29 filing was used to report a full week or more of daily transactions simultaneously. The $1,001 trade size is the minimum reportable bracket and remains consistent throughout the cluster. Across McCaul's 89 total disclosed LRLSQ trades, this pattern suggests the position was unwound over an extended period through small incremental sells, all reported en masse rather than on a rolling individual basis.

The December 13, 2019 sell of approximately $1,001 in LRLSQ was not disclosed until January 29, 2020, a 47-day gap that exceeds the STOCK Act's 45-day statutory filing deadline. This is the last of several consecutive daily trades in December that each carry statutory-level delays. From December 6 through December 13, 2019, McCaul's disclosed record shows a sell executed on every trading day, each at the minimum reportable value, and each filed on the same date weeks later. That pattern, visible here across 10 trades and broader across 89 total disclosures, points to a sustained divestiture strategy in LRLSQ that was disclosed in batch form rather than trade by trade. No member cluster was observed and no committee overlap can be established from available data.

This December 16, 2019 sell of approximately $1,001 in LRLSQ was filed on January 29, 2020, producing a 44-day delay. That delay exceeds Kapitol.ai's 30-day internal flag threshold but falls within the STOCK Act's 45-day statutory deadline, distinguishing it from several adjacent trades in this batch. The trade itself is minimal in value, at 0.07x the dataset median, and no peer cluster was active around this date. The December 16 trade marks the first in the latter half of December's selling sequence and, despite its slightly shorter delay relative to earlier trades, was still batched into the same January 29 filing. The cumulative effect across McCaul's 89 total LRLSQ disclosures is a picture of prolonged incremental liquidation reported in consolidated batches.

The December 18, 2019 sell of approximately $1,001 in LRLSQ carries a 42-day filing delay. That figure exceeds Kapitol.ai's 30-day internal flag threshold but remains within the STOCK Act's 45-day statutory window, making it a flagged-but-compliant disclosure from a legal standpoint. Like every other trade in this sample, it was batched into the January 29, 2020 filing. The $1,001 transaction size continues the pattern of minimum-bracket sells observed throughout the December 2019 sequence. With 89 total LRLSQ disclosures on record for McCaul, this individual trade is best read as one data point in a long-running liquidation of the position. No member cluster or committee overlap signals are present; the sole active signal is the late-disclosure flag.

This December 19, 2019 sell of approximately $1,001 in LRLSQ is the most recent of the ten trades analysed here, carrying a 41-day disclosure delay. That delay exceeds Kapitol.ai's internal 30-day threshold but falls within the STOCK Act's 45-day statutory window, so while flagged it does not constitute a statutory violation. All ten trades in this sample were filed simultaneously on January 29, 2020, reflecting a batch-reporting approach that compressed multiple weeks of daily sells into a single disclosure event. Across McCaul's 89 total LRLSQ disclosures, this trade sits at the most recent end of a prolonged selling sequence. The minimum $1,001 trade size, absence of peer clustering, and unverifiable committee relevance to a bankrupt retail entity mean the disclosure timing pattern is the primary analytical signal throughout this record.