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Feb 10

Jurisdiction as Structural Barrier: How Privacy Policy Organization May Reduce Visibility of Substantive Disclosures

Privacy policies are supposed to provide notice. But what if substantive information appears only where users skip it? We identify a structural pattern we call jurisdiction-siloed disclosure: information about data practices appearing in specific, actionable form only within regional compliance sections labeled "California Residents" or "EU/UK Users," while general sections use vague or qualified language for the same practices. Our audit of 123 major companies identifies 282 potential instances across 77 companies (62.6% of this purposive sample). A conservative estimate restricted to practice categories validated against OPP-115 human annotations finds 138 instances across 54 companies (44%); post-2018 categories central to our findings await independent validation. If users skip jurisdiction-labeled sections as information foraging theory predicts, users outside regulated jurisdictions would receive less specific information about practices affecting them--a transparency failure operating through document architecture rather than omission. We propose universal substantive disclosure: practices affecting all users should appear in the main policy body, with regional sections containing only procedural rights information. This standard finds support in analogous disclosure regimes (securities, truth-in-lending, nutritional labeling) where material information must reach all affected parties. Regulators could operationalize this through the FTC's "clear and conspicuous" standard and GDPR transparency principles. This work is hypothesis-generating: we establish that the structural pattern exists and ground the transparency concern in behavioral theory, but direct measurement of jurisdiction-specific section skipping remains the critical validation priority. We release our methodology and annotated dataset to enable replication.

  • 1 authors
·
Jan 28

Foresight Learning for SEC Risk Prediction

Risk disclosures in SEC filings describe potential adverse events but rarely quantify their likelihood, limiting their usefulness for probabilistic analysis. A central obstacle is the absence of large-scale, risk-level supervision linking disclosed risks to realized outcomes. We introduce a fully automated data generation pipeline that converts qualitative SEC risk disclosures into temporally grounded supervision using only public data. For each filing, the pipeline generates firm-specific, time-bounded risk queries from the Risk Factors section and labels them by automatically resolving outcomes against subsequent disclosures. Using this dataset of risk queries and outcomes grounded in SEC filings, we train a compact large language model to estimate the probability that a disclosed risk will materialize within a specified horizon. Despite its modest size, the resulting model substantially improves over pretrained and heuristic baselines, and outperforms frontier general-purpose models, including GPT-5, on probabilistic accuracy and calibration. More broadly, this work demonstrates that Foresight Learning enables scalable and fully automated training of domain-specific expert models using only raw, chronological, in-domain text -- without proprietary data, external corpora, or manual annotation. The resulting models achieve frontier-level performance while remaining deployable on a single GPU. This result suggests a general pathway for learning calibrated, decision-relevant signals from naturally occurring enterprise documents. To support transparency and reproducibility, we open-source the evaluation dataset used in this study. Evaluation Data: https://huggingface.co/datasets/LightningRodLabs/sec_risk_questions_test_set Data Generation Platform: https://lightningrod.ai/ SDK: https://github.com/lightning-rod-labs/lightningrod-python-sdk

  • 4 authors
·
Jan 26