The 5:30 Filing Cliff: Administrative Deadlines, Disclosure Timing, and Event-Time Measurement

Abstract

Public disclosure is not governed by a single timestamp. In the U.S. Securities and Exchange Commission's EDGAR system, the time a submission is accepted, the date legally assigned to it, and the time it becomes publicly available can diverge. For most forms, a direct transmission begun after 5:30 p.m. Eastern Time is assigned the next business day's filing date and is not disseminated until that day. I document this administrative discontinuity and study a 5 February 2024 reform that extended same-day treatment for Schedules 13D and 13G to 10:00 p.m. In a pilot covering 500 large current U.S.-listed issuers, Schedule 13G filings increased their post-5:30 share from 2.62% to 11.07%, while 8-K, 10-Q, and 10-K filings were nearly unchanged. A differencein-differences design with issuer, calendar month-day, and form fixed effects estimates a 12.71 percentage-point increase (CR1 two-way clustered standard error 6.88 points; p=0.066). The estimate is driven substantially by the annual February filing concentration: omitting February reduces it to 3.73 points (p=0.252), and none of six postaudit exploratory alternatives survives Holm adjustment. A daily-price illustration further shows that assigning shifted earnings filings to the acceptance date moves returns and volume away from the economically relevant availability date. The institutional evidence establishes a form-specific source of event-time measurement error; the behavioral estimate is economically large but statistically suggestive. The evidence does not support a maintained claim that firms use the cutoff to conceal bad news.

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