{
  "tool_id": "art-573-section16b-short-swing-profit-recompute",
  "note": "Vectors computed directly from the shipped kernel. Every insider, issuer, transaction and price here is SYNTHETIC and is not a copy of any real EDGAR Form 4/5 filing. Covers a two-pair MATCHES case, an exempt-exclusion + HFIAA-asymmetry DIVERGES case, and the empty-transaction-list INDETERMINATE finite-gate state.",
  "vectors": [
    {
      "name": "matches-lowest-in-highest-out",
      "description": "A domestic officer/director insider with two purchases at different prices and one sale. The lowest-priced purchase is matched first against the sale (Smolowe lowest-in/highest-out), then the next-lowest, for a two-pair total that agrees with the demand letter claimed profit.",
      "policy_parameters": {
        "insider_ref": "SYNTH-INSIDER-001",
        "issuer_ref": "SYNTH-ISSUER-CO",
        "currency": "USD",
        "transactions": [
          {
            "txn_id": "txn-1",
            "type": "buy",
            "date": "2026-01-10",
            "price_minor_units": 1000,
            "shares": 100
          },
          {
            "txn_id": "txn-2",
            "type": "buy",
            "date": "2026-02-10",
            "price_minor_units": 1200,
            "shares": 100
          },
          {
            "txn_id": "txn-3",
            "type": "sell",
            "date": "2026-04-01",
            "price_minor_units": 2000,
            "shares": 150
          }
        ],
        "insider_status": {
          "officer_or_director": true,
          "ten_pct_owner": false,
          "foreign_private_issuer": false
        },
        "demand_letter_claimed_profit_minor_units": 140000
      },
      "output_payload": {
        "insider_ref": "SYNTH-INSIDER-001",
        "issuer_ref": "SYNTH-ISSUER-CO",
        "currency": "USD",
        "minor_unit_exponent": 2,
        "transaction_count": 3,
        "usable_transaction_count": 3,
        "excluded_transactions": [],
        "purchase_count": 2,
        "sale_count": 1,
        "matched_pairs": [
          {
            "purchase_txn_id": "txn-1",
            "purchase_date": "2026-01-10",
            "purchase_price_minor_units": 1000,
            "purchase_price_display": "10.00",
            "sale_txn_id": "txn-3",
            "sale_date": "2026-04-01",
            "sale_price_minor_units": 2000,
            "sale_price_display": "20.00",
            "shares_matched": 100,
            "profit_minor_units": 100000,
            "profit_display": "1000.00",
            "day_gap": 81,
            "window_basis": "81 day(s) apart, matched against a 183-day approximation of the statutory less-than-six-months window (day-count approximation, not calendar-month arithmetic; see not_proven)."
          },
          {
            "purchase_txn_id": "txn-2",
            "purchase_date": "2026-02-10",
            "purchase_price_minor_units": 1200,
            "purchase_price_display": "12.00",
            "sale_txn_id": "txn-3",
            "sale_date": "2026-04-01",
            "sale_price_minor_units": 2000,
            "sale_price_display": "20.00",
            "shares_matched": 50,
            "profit_minor_units": 40000,
            "profit_display": "400.00",
            "day_gap": 50,
            "window_basis": "50 day(s) apart, matched against a 183-day approximation of the statutory less-than-six-months window (day-count approximation, not calendar-month arithmetic; see not_proven)."
          }
        ],
        "unmatched_purchase_shares": 50,
        "unmatched_sale_shares": 0,
        "total_profit_minor_units": 140000,
        "total_profit_display": "1400.00",
        "six_month_window_day_threshold": 183,
        "insider_status": {
          "officer_or_director": true,
          "ten_pct_owner": false,
          "foreign_private_issuer": false
        },
        "section_16a_applicability": {
          "is_16a_filer": true,
          "is_16b_liable": true,
          "basis": "Domestic insider: officer/director or 10%-owner status makes this insider both a Section 16(a) filer and subject to Section 16(b) short-swing profit-recovery liability."
        },
        "demand_letter_supplied": true,
        "demand_letter_claimed_profit_minor_units": 140000,
        "demand_letter_claimed_profit_display": "1400.00",
        "comparison_basis": "The recomputed matched-pair total is derived here from the declared transaction list using the lowest-in/highest-out construction; it is not read from the demand letter. A comparison is only meaningful because the two sides have independent provenance.",
        "difference_minor_units": 0,
        "difference_display": "0.00",
        "verdict": "MATCHES",
        "indeterminate_reason": null,
        "rejected_inputs": [],
        "citations": {
          "section_16b": {
            "source": "Securities Exchange Act of 1934 Sec. 16(b), 15 U.S.C. Sec. 78p(b)",
            "detail": "Strict-liability disgorgement of any profit realized by a Section 16 insider from any purchase and sale, or sale and purchase, of the issuer's equity security within a period of less than six months."
          },
          "smolowe_maximal_recovery": {
            "source": "Smolowe v. Delvag Reinsurance Co., 136 F.2d 231 (2d Cir. 1943); Gratz v. Claughton, 187 F.2d 46 (2d Cir. 1951)",
            "detail": "The \"lowest price in, highest price out\" matching construction, maximizing recovery to the corporation rather than measuring the insider's actual realized gain; losses on other pairings are never netted against a profitable pairing. Re-verify against primary case text before relying on it (research finding, not fact)."
          },
          "rule_16b3": {
            "source": "17 CFR 240.16b-3",
            "detail": "Exempts certain transactions between an issuer and its officers/directors under an approved plan (e.g. grants, tax-withholding transactions) from Section 16(b) matching. This kernel excludes a transaction from matching only when the caller declares an exemption_flags entry for it; it makes no independent exemption determination."
          },
          "section_16a_general": {
            "source": "Securities Exchange Act of 1934 Sec. 16(a), 15 U.S.C. Sec. 78p(a)",
            "detail": "Reporting obligation for officers, directors, and beneficial owners of more than 10% of a registered equity security."
          },
          "rule_3a12_3": {
            "source": "17 CFR 240.3a12-3(b)",
            "detail": "Historically exempted a foreign private issuer and its officers, directors, and 10%-owners from Section 16 (both (a) and (b)) entirely."
          },
          "hfiaa": {
            "source": "Holding Foreign Insiders Accountable Act, FY2026 NDAA, signed 2025-12-18",
            "detail": "Makes officers and directors of a foreign private issuer Section 16(a) reporting filers for the first time. Expressly does NOT extend Section 16(b) short-swing profit-recovery liability to that population, and does not disturb the Rule 3a12-3(b) exemption for a 10%-owner who is not also an officer or director. Re-verify against primary text before relying on it (research finding, not fact)."
          }
        },
        "rationale": [
          "Section 16(b) matchable-pair recompute for insider reference SYNTH-INSIDER-001 on issuer reference SYNTH-ISSUER-CO.",
          "3 of 3 declared transaction(s) were usable and non-exempt; 0 were excluded (unusable input or a declared exemption).",
          "2 purchase(s) and 1 sale(s) were eligible for matching. Matching applied the lowest-in/highest-out construction: the lowest-priced eligible purchase was paired against the highest-priced eligible sale, repeatedly, within a 183-day approximation of the statutory less-than-six-months window, and a pairing that would produce a loss was skipped rather than netted.",
          "2 matched pair(s) were found, for a total recomputed profit of 1400.00 USD.",
          "50 purchased share(s) and 0 sold share(s) remained unmatched (no eligible profitable in-window counterparty).",
          "Domestic insider: officer/director or 10%-owner status makes this insider both a Section 16(a) filer and subject to Section 16(b) short-swing profit-recovery liability.",
          "The independently recomputed matched-pair total agrees with the demand letter's claimed profit of 1400.00 USD.",
          "This is not legal advice. The six-month window applied here is a day-count approximation of the statutory calendar-month boundary, and no exemption was independently determined -- both are named in not_proven. No computed figure resolves a matchability or exemption dispute."
        ],
        "not_proven": [
          {
            "item": "Not legal advice",
            "detail": "This kernel recomputes a matchable-pair short-swing profit figure from caller-declared transaction facts. It is not a substitute for counsel, and no computed figure resolves a matchability or exemption dispute."
          },
          {
            "item": "Six-month window is a day-count approximation",
            "detail": "The statutory \"less than six months\" boundary is approximated here as strictly less than 183 days apart rather than true calendar-month arithmetic. A pair straddling the 182/183-day boundary needs independent calendar-month verification."
          },
          {
            "item": "Algorithm re-verification",
            "detail": "The lowest-in/highest-out maximal-recovery construction is the widely cited Smolowe/Gratz heuristic, but this kernel's citation of it was not re-derived from primary case text at build time (research finding, not fact per the build row)."
          },
          {
            "item": "Exemption determinations are caller-declared",
            "detail": "A transaction is excluded from matching only because the caller declared an exemption_flags entry for it (e.g. Rule 16b-3). This kernel makes no independent determination that any exemption in fact applies."
          },
          {
            "item": "Rule 144 volume limitation",
            "detail": "Whether a sale complies with Rule 144 volume limitations is out of scope; it is a named follow-on tool, not computed here."
          },
          {
            "item": "Input accuracy",
            "detail": "Every transaction's date, price, and share count, and the insider_status flags, are caller-supplied and asserted, not independently verified against EDGAR Form 4/5 filings."
          }
        ],
        "fence": "This is not legal advice. It does not compute a Rule 144 volume-limitation check (a named follow-on tool). Matching uses the lowest-in/highest-out construction over caller-declared transactions and a day-count approximation of the six-month window; a declared exemption excludes a transaction from matching without this kernel independently determining whether that exemption applies. No computed figure resolves a matchability or exemption dispute, which is counsel's.",
        "note": "Deterministic Section 16(b) matchable-pair short-swing profit recompute over a caller-declared transaction list. Single-run and stateless: it holds no records, runs on no schedule, and retains nothing."
      },
      "golden_hash": "19aca79a89945fd812e70126ea103d676ca7a18b2a3f60672fb7ec04e4b74cad"
    },
    {
      "name": "diverges-with-exempt-exclusion-and-hfiaa-asymmetry",
      "description": "A foreign-private-issuer officer/director. One purchase carries a declared Rule 16b-3 exemption and is excluded from matching. HFIAA makes this insider a Section 16(a) filer but the kernel flags that Section 16(b) liability is NOT extended. The recomputed matched-pair total diverges from the demand letter.",
      "policy_parameters": {
        "insider_ref": "SYNTH-INSIDER-002",
        "issuer_ref": "SYNTH-ISSUER-FPI",
        "currency": "USD",
        "transactions": [
          {
            "txn_id": "txn-1",
            "type": "buy",
            "date": "2026-01-01",
            "price_minor_units": 500,
            "shares": 50
          },
          {
            "txn_id": "txn-2",
            "type": "buy",
            "date": "2026-01-05",
            "price_minor_units": 800,
            "shares": 50,
            "exemption_flags": [
              "rule_16b-3"
            ]
          },
          {
            "txn_id": "txn-3",
            "type": "sell",
            "date": "2026-03-01",
            "price_minor_units": 1500,
            "shares": 50
          }
        ],
        "insider_status": {
          "officer_or_director": true,
          "ten_pct_owner": false,
          "foreign_private_issuer": true
        },
        "demand_letter_claimed_profit_minor_units": 65000
      },
      "output_payload": {
        "insider_ref": "SYNTH-INSIDER-002",
        "issuer_ref": "SYNTH-ISSUER-FPI",
        "currency": "USD",
        "minor_unit_exponent": 2,
        "transaction_count": 3,
        "usable_transaction_count": 2,
        "excluded_transactions": [
          {
            "txn_id": "txn-2",
            "type": "buy",
            "date": "2026-01-05",
            "days": 20458,
            "price_minor_units": 800,
            "price_display": "8.00",
            "shares": 50,
            "exemption_flags": [
              "rule_16b-3"
            ],
            "exclusion_reason": "declared exemption: rule_16b-3"
          }
        ],
        "purchase_count": 1,
        "sale_count": 1,
        "matched_pairs": [
          {
            "purchase_txn_id": "txn-1",
            "purchase_date": "2026-01-01",
            "purchase_price_minor_units": 500,
            "purchase_price_display": "5.00",
            "sale_txn_id": "txn-3",
            "sale_date": "2026-03-01",
            "sale_price_minor_units": 1500,
            "sale_price_display": "15.00",
            "shares_matched": 50,
            "profit_minor_units": 50000,
            "profit_display": "500.00",
            "day_gap": 59,
            "window_basis": "59 day(s) apart, matched against a 183-day approximation of the statutory less-than-six-months window (day-count approximation, not calendar-month arithmetic; see not_proven)."
          }
        ],
        "unmatched_purchase_shares": 0,
        "unmatched_sale_shares": 0,
        "total_profit_minor_units": 50000,
        "total_profit_display": "500.00",
        "six_month_window_day_threshold": 183,
        "insider_status": {
          "officer_or_director": true,
          "ten_pct_owner": false,
          "foreign_private_issuer": true
        },
        "section_16a_applicability": {
          "is_16a_filer": true,
          "is_16b_liable": false,
          "basis": "Foreign private issuer officer/director: HFIAA (signed 2025-12-18) makes this insider a Section 16(a) reporting filer for the first time, but expressly does NOT extend Section 16(b) short-swing profit-recovery liability to this population -- the matched-pair figure above is informational only for this insider."
        },
        "demand_letter_supplied": true,
        "demand_letter_claimed_profit_minor_units": 65000,
        "demand_letter_claimed_profit_display": "650.00",
        "comparison_basis": "The recomputed matched-pair total is derived here from the declared transaction list using the lowest-in/highest-out construction; it is not read from the demand letter. A comparison is only meaningful because the two sides have independent provenance.",
        "difference_minor_units": -15000,
        "difference_display": "-150.00",
        "verdict": "DIVERGES",
        "indeterminate_reason": null,
        "rejected_inputs": [],
        "citations": {
          "section_16b": {
            "source": "Securities Exchange Act of 1934 Sec. 16(b), 15 U.S.C. Sec. 78p(b)",
            "detail": "Strict-liability disgorgement of any profit realized by a Section 16 insider from any purchase and sale, or sale and purchase, of the issuer's equity security within a period of less than six months."
          },
          "smolowe_maximal_recovery": {
            "source": "Smolowe v. Delvag Reinsurance Co., 136 F.2d 231 (2d Cir. 1943); Gratz v. Claughton, 187 F.2d 46 (2d Cir. 1951)",
            "detail": "The \"lowest price in, highest price out\" matching construction, maximizing recovery to the corporation rather than measuring the insider's actual realized gain; losses on other pairings are never netted against a profitable pairing. Re-verify against primary case text before relying on it (research finding, not fact)."
          },
          "rule_16b3": {
            "source": "17 CFR 240.16b-3",
            "detail": "Exempts certain transactions between an issuer and its officers/directors under an approved plan (e.g. grants, tax-withholding transactions) from Section 16(b) matching. This kernel excludes a transaction from matching only when the caller declares an exemption_flags entry for it; it makes no independent exemption determination."
          },
          "section_16a_general": {
            "source": "Securities Exchange Act of 1934 Sec. 16(a), 15 U.S.C. Sec. 78p(a)",
            "detail": "Reporting obligation for officers, directors, and beneficial owners of more than 10% of a registered equity security."
          },
          "rule_3a12_3": {
            "source": "17 CFR 240.3a12-3(b)",
            "detail": "Historically exempted a foreign private issuer and its officers, directors, and 10%-owners from Section 16 (both (a) and (b)) entirely."
          },
          "hfiaa": {
            "source": "Holding Foreign Insiders Accountable Act, FY2026 NDAA, signed 2025-12-18",
            "detail": "Makes officers and directors of a foreign private issuer Section 16(a) reporting filers for the first time. Expressly does NOT extend Section 16(b) short-swing profit-recovery liability to that population, and does not disturb the Rule 3a12-3(b) exemption for a 10%-owner who is not also an officer or director. Re-verify against primary text before relying on it (research finding, not fact)."
          }
        },
        "rationale": [
          "Section 16(b) matchable-pair recompute for insider reference SYNTH-INSIDER-002 on issuer reference SYNTH-ISSUER-FPI.",
          "2 of 3 declared transaction(s) were usable and non-exempt; 1 were excluded (unusable input or a declared exemption).",
          "1 purchase(s) and 1 sale(s) were eligible for matching. Matching applied the lowest-in/highest-out construction: the lowest-priced eligible purchase was paired against the highest-priced eligible sale, repeatedly, within a 183-day approximation of the statutory less-than-six-months window, and a pairing that would produce a loss was skipped rather than netted.",
          "1 matched pair(s) were found, for a total recomputed profit of 500.00 USD.",
          "Foreign private issuer officer/director: HFIAA (signed 2025-12-18) makes this insider a Section 16(a) reporting filer for the first time, but expressly does NOT extend Section 16(b) short-swing profit-recovery liability to this population -- the matched-pair figure above is informational only for this insider.",
          "The independently recomputed matched-pair total of 500.00 USD diverges from the demand letter's claimed profit of 650.00 USD by -150.00 USD. This is an arithmetic finding about the transactions supplied here, not a determination of matchability or exemption, which is counsel's.",
          "This is not legal advice. The six-month window applied here is a day-count approximation of the statutory calendar-month boundary, and no exemption was independently determined -- both are named in not_proven. No computed figure resolves a matchability or exemption dispute."
        ],
        "not_proven": [
          {
            "item": "Not legal advice",
            "detail": "This kernel recomputes a matchable-pair short-swing profit figure from caller-declared transaction facts. It is not a substitute for counsel, and no computed figure resolves a matchability or exemption dispute."
          },
          {
            "item": "Six-month window is a day-count approximation",
            "detail": "The statutory \"less than six months\" boundary is approximated here as strictly less than 183 days apart rather than true calendar-month arithmetic. A pair straddling the 182/183-day boundary needs independent calendar-month verification."
          },
          {
            "item": "Algorithm re-verification",
            "detail": "The lowest-in/highest-out maximal-recovery construction is the widely cited Smolowe/Gratz heuristic, but this kernel's citation of it was not re-derived from primary case text at build time (research finding, not fact per the build row)."
          },
          {
            "item": "Exemption determinations are caller-declared",
            "detail": "A transaction is excluded from matching only because the caller declared an exemption_flags entry for it (e.g. Rule 16b-3). This kernel makes no independent determination that any exemption in fact applies."
          },
          {
            "item": "Rule 144 volume limitation",
            "detail": "Whether a sale complies with Rule 144 volume limitations is out of scope; it is a named follow-on tool, not computed here."
          },
          {
            "item": "Input accuracy",
            "detail": "Every transaction's date, price, and share count, and the insider_status flags, are caller-supplied and asserted, not independently verified against EDGAR Form 4/5 filings."
          }
        ],
        "fence": "This is not legal advice. It does not compute a Rule 144 volume-limitation check (a named follow-on tool). Matching uses the lowest-in/highest-out construction over caller-declared transactions and a day-count approximation of the six-month window; a declared exemption excludes a transaction from matching without this kernel independently determining whether that exemption applies. No computed figure resolves a matchability or exemption dispute, which is counsel's.",
        "note": "Deterministic Section 16(b) matchable-pair short-swing profit recompute over a caller-declared transaction list. Single-run and stateless: it holds no records, runs on no schedule, and retains nothing."
      },
      "golden_hash": "9511e31d202255f5bc6aa1d361cf403c7abe2af78e59949337a03f728a841215"
    },
    {
      "name": "indeterminate-empty-transaction-list",
      "description": "No transactions were supplied at all -- the finite gate resolves this to INDETERMINATE rather than a zero-profit MATCHES, since there is nothing to match.",
      "policy_parameters": {
        "insider_ref": "SYNTH-INSIDER-003",
        "issuer_ref": "SYNTH-ISSUER-CO",
        "currency": "USD",
        "transactions": []
      },
      "output_payload": {
        "insider_ref": "SYNTH-INSIDER-003",
        "issuer_ref": "SYNTH-ISSUER-CO",
        "currency": "USD",
        "minor_unit_exponent": 2,
        "transaction_count": 0,
        "usable_transaction_count": 0,
        "excluded_transactions": [],
        "purchase_count": 0,
        "sale_count": 0,
        "matched_pairs": [],
        "unmatched_purchase_shares": 0,
        "unmatched_sale_shares": 0,
        "total_profit_minor_units": 0,
        "total_profit_display": "0.00",
        "six_month_window_day_threshold": 183,
        "insider_status": {
          "officer_or_director": false,
          "ten_pct_owner": false,
          "foreign_private_issuer": false
        },
        "section_16a_applicability": {
          "is_16a_filer": false,
          "is_16b_liable": false,
          "basis": "No officer/director or 10%-owner status was declared; this insider is not a Section 16(a) filer or Section 16(b)-liable insider on the facts declared."
        },
        "demand_letter_supplied": false,
        "demand_letter_claimed_profit_minor_units": null,
        "demand_letter_claimed_profit_display": null,
        "comparison_basis": "The recomputed matched-pair total is derived here from the declared transaction list using the lowest-in/highest-out construction; it is not read from the demand letter. A comparison is only meaningful because the two sides have independent provenance.",
        "difference_minor_units": null,
        "difference_display": null,
        "verdict": "INDETERMINATE",
        "indeterminate_reason": "No usable, non-exempt transactions were supplied, so no matchable pairs could be computed.",
        "rejected_inputs": [],
        "citations": {
          "section_16b": {
            "source": "Securities Exchange Act of 1934 Sec. 16(b), 15 U.S.C. Sec. 78p(b)",
            "detail": "Strict-liability disgorgement of any profit realized by a Section 16 insider from any purchase and sale, or sale and purchase, of the issuer's equity security within a period of less than six months."
          },
          "smolowe_maximal_recovery": {
            "source": "Smolowe v. Delvag Reinsurance Co., 136 F.2d 231 (2d Cir. 1943); Gratz v. Claughton, 187 F.2d 46 (2d Cir. 1951)",
            "detail": "The \"lowest price in, highest price out\" matching construction, maximizing recovery to the corporation rather than measuring the insider's actual realized gain; losses on other pairings are never netted against a profitable pairing. Re-verify against primary case text before relying on it (research finding, not fact)."
          },
          "rule_16b3": {
            "source": "17 CFR 240.16b-3",
            "detail": "Exempts certain transactions between an issuer and its officers/directors under an approved plan (e.g. grants, tax-withholding transactions) from Section 16(b) matching. This kernel excludes a transaction from matching only when the caller declares an exemption_flags entry for it; it makes no independent exemption determination."
          },
          "section_16a_general": {
            "source": "Securities Exchange Act of 1934 Sec. 16(a), 15 U.S.C. Sec. 78p(a)",
            "detail": "Reporting obligation for officers, directors, and beneficial owners of more than 10% of a registered equity security."
          },
          "rule_3a12_3": {
            "source": "17 CFR 240.3a12-3(b)",
            "detail": "Historically exempted a foreign private issuer and its officers, directors, and 10%-owners from Section 16 (both (a) and (b)) entirely."
          },
          "hfiaa": {
            "source": "Holding Foreign Insiders Accountable Act, FY2026 NDAA, signed 2025-12-18",
            "detail": "Makes officers and directors of a foreign private issuer Section 16(a) reporting filers for the first time. Expressly does NOT extend Section 16(b) short-swing profit-recovery liability to that population, and does not disturb the Rule 3a12-3(b) exemption for a 10%-owner who is not also an officer or director. Re-verify against primary text before relying on it (research finding, not fact)."
          }
        },
        "rationale": [
          "Section 16(b) matchable-pair recompute for insider reference SYNTH-INSIDER-003 on issuer reference SYNTH-ISSUER-CO.",
          "0 of 0 declared transaction(s) were usable and non-exempt; 0 were excluded (unusable input or a declared exemption).",
          "0 purchase(s) and 0 sale(s) were eligible for matching. Matching applied the lowest-in/highest-out construction: the lowest-priced eligible purchase was paired against the highest-priced eligible sale, repeatedly, within a 183-day approximation of the statutory less-than-six-months window, and a pairing that would produce a loss was skipped rather than netted.",
          "No profitable, in-window pairing was found.",
          "No officer/director or 10%-owner status was declared; this insider is not a Section 16(a) filer or Section 16(b)-liable insider on the facts declared.",
          "Verdict is INDETERMINATE: No usable, non-exempt transactions were supplied, so no matchable pairs could be computed.",
          "This is not legal advice. The six-month window applied here is a day-count approximation of the statutory calendar-month boundary, and no exemption was independently determined -- both are named in not_proven. No computed figure resolves a matchability or exemption dispute."
        ],
        "not_proven": [
          {
            "item": "Not legal advice",
            "detail": "This kernel recomputes a matchable-pair short-swing profit figure from caller-declared transaction facts. It is not a substitute for counsel, and no computed figure resolves a matchability or exemption dispute."
          },
          {
            "item": "Six-month window is a day-count approximation",
            "detail": "The statutory \"less than six months\" boundary is approximated here as strictly less than 183 days apart rather than true calendar-month arithmetic. A pair straddling the 182/183-day boundary needs independent calendar-month verification."
          },
          {
            "item": "Algorithm re-verification",
            "detail": "The lowest-in/highest-out maximal-recovery construction is the widely cited Smolowe/Gratz heuristic, but this kernel's citation of it was not re-derived from primary case text at build time (research finding, not fact per the build row)."
          },
          {
            "item": "Exemption determinations are caller-declared",
            "detail": "A transaction is excluded from matching only because the caller declared an exemption_flags entry for it (e.g. Rule 16b-3). This kernel makes no independent determination that any exemption in fact applies."
          },
          {
            "item": "Rule 144 volume limitation",
            "detail": "Whether a sale complies with Rule 144 volume limitations is out of scope; it is a named follow-on tool, not computed here."
          },
          {
            "item": "Input accuracy",
            "detail": "Every transaction's date, price, and share count, and the insider_status flags, are caller-supplied and asserted, not independently verified against EDGAR Form 4/5 filings."
          }
        ],
        "fence": "This is not legal advice. It does not compute a Rule 144 volume-limitation check (a named follow-on tool). Matching uses the lowest-in/highest-out construction over caller-declared transactions and a day-count approximation of the six-month window; a declared exemption excludes a transaction from matching without this kernel independently determining whether that exemption applies. No computed figure resolves a matchability or exemption dispute, which is counsel's.",
        "note": "Deterministic Section 16(b) matchable-pair short-swing profit recompute over a caller-declared transaction list. Single-run and stateless: it holds no records, runs on no schedule, and retains nothing."
      },
      "golden_hash": "c38506e110e1fdeaabe4fe843cc9f796a57eeba37fbfc31598bbea58ad876316"
    }
  ]
}