Corral the deal record out of the drafts, mailboxes and drives it scattered into, test each answer against the document behind it, and hold the assembled file for the officer who signs.
A deal is signed, and § 803.6 gives the certification to an officer or director.
02
A waiting period opens, and 15 U.S.C. § 18a(b)(1) runs thirty days from receipt.
Reason
03
A cash tender offer or a bankruptcy sale runs fifteen days under § 803.10.
04
A Second Request lands, and § 803.6(b) puts a fresh certification on the response.
05
A filing is pulled, and § 803.12 wants it recertified within two business days.
Decide
06
A covered transaction approaches, and § 800.401(g)(2) sets thirty days before completion.
07
A declaration is filed, and § 800.405(b) starts thirty days of assessment.
Out
08
A notifiable outbound deal completes, and § 850.404(c) leaves thirty calendar days.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
Assembly and both clocks belong to the agent. An officer or director certifies the HSR filing; the chief executive or a duly authorized designee certifies the CFIUS one.
2Filing context assembledThe transaction, the parties standing behind it, the regime it answers to and the day its clock started
3Answer evidence draftedThe question, the documents under it, the gaps and completeness
4Controls appliedCustodian checks, de-duplication checks, clock checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and no certification happens at any of them — the agent is only assembling, and counsel enters at the completeness gate.
5DecisionSplits at the completeness gate
Evidence sufficient
Passes to the certifying officer for signature.
Anything thin
Adds a deal counsel read first.
Counsel review
The filing is held with its answers, its gaps and the custodians they came from.
Certify · Append evidence · Send to counsel review
Certified — by an officer or director▼
6Deal and filing records updatedOnly where write access and records policy allow it
7Outcome evaluatedDocument completeness, clock coverage, counsel corrections and what review found
Corrections
Each counsel correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Certifying an HSR filing under 16 CFR § 803.6.
Signing the § 800.204 certification for a party.
Deciding that a document is not responsive.
Choosing who holds actual authority to sign.
Automation boundaryAgent acts unaided
✓Build the custodian map from the officers and directors named.
✓Collect and de-duplicate the deal documents held.
✓Run both clocks and raise the two-business-day recertification.
✓Test every drafted answer against the document held.
No certification is signed and no filing goes out except by a named person, on approval.
Judging whether a transaction is reportable.
Telling an agency the filing is complete.
Predicting whether early termination will be granted.
Changes to the filing, the log or the custodian map.
Example output
One filing answer, annotated
Our deal-underwriting due-diligence copilot reconciles asset-level financials for a discretionary investment committee; this assembles sworn narrative evidence for a government filing on a statutory clock.
Filing answer · single questionIllustrative example
Answer
Recorded as
Question
Evidence of record
Confidence
Held for
Competitive overlap, Item 4(c)
Drawn from the documents each custodian named
Overlap narrative
Board paper, 3 August 2026
Held uncertified
The certifying officer, by name
As receivedTaken from the board papers and the custodian mailboxes — it reaches no further than those sources.
What the record holdsBoard paperBankers' modelDraft strategy deck
Why nothing is sworn hereWhether the file is true, correct, and complete is a sworn judgement.
ActionCertifyAppend evidenceSend to counsel review
What the score decidesBelow the configured threshold a filing picks up a counsel read before the officer sees it.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every answerFrom the custodian who holds it
03Evidence
Where the evidence is used
A filing record is not a legal opinion: this page shows what was collected and what each answer rests on, and it makes no call on whether a deal is reportable.
01Approved path
One deal, several oaths
The HSR certification is notarised or made under penalty of perjury per 28 U.S.C. § 1746; CFIUS and outbound run under 18 U.S.C. § 1001.
02Human review
What was checked, and not found
The presidential decision window is statutory and does not sit in Part 800, so it is not stated here; no CFIUS fee or penalty figure is published on this page; and the declaration wording of the EU Form CO and Form FS-CO could not be retrieved verbatim, so neither is quoted.
04Build an evidence trail
The filing, the document behind each answer and the officer who certified stay together.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Deal team and custodiansMailboxes · shared drives Draft decks and deal-team files
Board and governanceBoard portal · minute book Board papers and resolutions
Corporate structureCap table · entity register Ownership and control records
Agent
M&A deal filing evidence
Reads the requests Assembles the file Holds for the officer
Advisers and data roomsBankers · counsel · data room Models, drafts and exhibit lists
Integration availability depends on the client's existing systems and API access.
Agent controls
Six turnstiles between the model and the officer
Six turnstiles in a row, the last admitting fewest. Whoever passes them all is named in the map below.
L6 · Outermost — last line of defenceInward → L1 · closest to the model
L6Rollback / safe modeNarrow the agent to evidence assembly when evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt and filing rules; the 2024 HSR form was vacated on 12 February 2026, and § 803.6, whose amendment history stops in 1983, was untouched by it.Track
L4TraceabilityRecord each answer, the documents under it, the custodian it came from and every read of the file.Record
L3Officer releaseHold the file for an officer or director possessing actual authority under § 803.6(c); the hold governs release, not whether an answer is complete.Gate
L2Custodian guardrailsTest the collection against the named custodians and the request; § 800.404(d) and § 800.502 make each party certify its own submission separately.Restrict
L1Confidence thresholdsRoute a thin filing to a counsel read first; § 800.508 allows forty-five days of investigation and a single extension of fifteen.Require review
Model coreEvidence assembled — the answer, its documents, the clocks and completeness
L1 – L2Test whether an answer may stand
L3Leaves the certification to a named person
L4 – L5Keep the filing and the document behind it
L6Holds the filing uncertified when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the filing answer that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the filing an agency reads
Depth of coverage ▼
E1Final-output evaluationDid the answer record what the documents actually show?
E2Step-level evaluationDid the agent read the right custodian, the right request and the live entity list?
E3Tool evaluationDid it read and write the correct deal record and the correct filing?
E4Confidence calibrationDo low-confidence filings actually attract more counsel corrections?
E5Slice evaluationHow does performance change across specific filing types?
E6Business outcomeHow many filings needed a correction before the officer certified?
Floor — the filing the company answers for
Failure modes
Where each failure originates in the agent
Seven failure modes, each pinned to the stage where it first shows.
Agent lifecycleDirection of processing →
01 · Retrieval1 mode
LT-03
Stale custodian read
The custodian list is not the one the deal team now works to.
Stage gathersThe deals, the requests, the drafts and the dates
02 · Reasoning2 modes
LT-04
Answer asserted, not shown
An answer is drafted with no document under it.
LT-06
Vacated form read as live
A withdrawn form is worked as the operative one.
Stage proposesThe answers, their documents and completeness
03 · Tool / write2 modes
LT-02
Thin filing passed forward
A filing moves on without the counsel read.
LT-05
Wrong party on the document
The document is bound to the other side of the deal.
Stage writesOnly where write access and approval policy allow it
04 · Output1 mode
LT-01
Sworn, evidence unrecorded
The file shows a signature but not the documents under it.
Stage returnsThe filing an officer signs and an agency reads
05 · Change / Version1 mode
LT-07
Silent deadline drift
A release shifts the deadline while the filing keeps the old one.
Stage tracksModel, prompt, filing rules and answer fields
Sev-1 · a filing certified on no documentSev-2 · wrong document reaches the filingSev-3 · source degrades, filing held back
A filing-level document-completeness figure can read clean while Second Request responses carry most of the rework. Nestack reports the correction rate by filing type, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Second Request responses
11.1%
3.7×
Review
Initial HSR notifications
7.9%
2.6×
Review
CFIUS declarations and notices
4.9%
1.6×
Watch
Outbound notifications
1.9%
0.6×
Normal
Bar: correction-rate lift vs. outbound notification baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What a missed document costs
A loop ends when the missed deal document has become a case the next release must pass. That suite is what the next filing assembled is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Correction rate rises on Second Request responses.
02Diagnose
The deal folder on one director's laptop that the sworn filing said did not exist is read back until a single cause remains.
03Improve
Number the change; the filings that drove it are filed underneath it.
04Verify
Each touched filing case is run once more, and one red holds it back.
05Learn
It stays on as a standing test, and the collection rules travel with it.
Learn → DetectThe return edge. The next filing is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, filing assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Certification-boundary and custodian-map work.
02Custodian, board and adviser sources.
03Answer-to-document and clock-coverage mapping.
04Deal document ingestion.
05Answer, document and party binding.
06Completeness scoring and review routing.
07Officer certification workflow.
08Data-room and mailbox integration.
09Custodian and completeness cases.
10Guardrails and certification controls.
11Filing-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne deal, one regimeProductionProduction filing workflowAdvancedMultiple regimes / entities
Introduced at Pilot
Answer assembly to your requests✓✓✓
Certifying officer release✓✓✓
Deal-document baseline✓✓✓
Introduced at Production
Reporting by filing—✓✓
Officer sign-off workflow in your systems—✓✓
Approved write-back—✓✓
Custodian-mailbox integration—✓✓
Introduced at Advanced
Multi-party filings——✓
Cross-regime evidence packs——✓
Large document estates——✓
Multi-regime deadline controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, document volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your live deals and the custodians behind each one→Custodian mapping and document captureWeek 1
02Representative board, adviser and deal-team documents→Document binding, answer logic and the filing baselineWeek 2
03Your standing filing procedure and the signers it names→Request mapping, clock binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Custodian, board and adviser source assessment, then integration setupWeek 2
05Filings you would not want sworn→Completeness cases and the evaluation runWeek 4
06What no filing record may settle→Completeness scoring, review routing, guardrails and release controlsWeek 3
07An officer or director who possesses actual authority→Release to the certifying officer, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Phase widths follow the effort each one costs rather than the grid, so one week does double duty.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Filing workflow discovery, custodian mapping and the automation boundaryW2Source integration and the deal-document baselineW3Answer assembly, clock logic and release controlsW4Evaluation suite, completeness cases and failure-mode testingW5Data-room integration, pilot filings and targeted correctionsW6One deal cycle run under the certifying officer, then Agent Care handover
Reading the bandEach bar spans the weeks its own work is named for, and the fifth holds two because the work does.
At the end of W6When the filing record validates, Agent Care takes the agent on.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Strategy AI agent
Build a deal filing agent around the document nobody remembered writing.
Show us one answer and the document under it. Only § 803.6 says who certifies an HSR filing: any officer or director of the filing person, possessing actual authority. Under § 800.204 and § 850.203 it is the chief executive or a duly authorized designee.
