# Item 703 Repurchase Evidence - Release Certification Report (item703-repurchase-evidence-2025-09-30-r1)

**Decision: ITEM 703 RELEASE GATE: PASS** (blockers: 0). The certification decision is Persistfolio's own; it is not a third-party certification. No external audit has been performed on this release.

## 1. Certified run
| | |
| --- | --- |
| Workflow run | 37794101419 (`item703-cohort-manufacturing.yml`) |
| Source commit | `cad2f7b88b40265e607c674a397123a732341fea` |
| Configuration | 24 shards, full cohort, no sample/CIK/accession filter, 3 SEC requests/second per shard, SEC response cache off |
| Shards | 24/24 |
| Issuers | 971/971 completed, 0 failed |
| Cohort checksums | verified on every shard: true |
| Identity overlay | `ca22f01424779e8c26fe2d14724f5a36a454f61a80726fff9db982cd7c82bd36` (one value on every shard) |
| Manufacturing window | 2026-10-08T14:38:51.195Z to 2026-10-08T15:49:05.829Z |

## 2. Reconstructed cohort basis
Persistfolio Historical Cohort Release 1.1 (2004-09-30 to 2025-09-30), 978 securities, intersected with the Item 703 working identity overlay; 971 CIKs; scope = filings whose verified period of report is inside the filer's membership window, falling back to the filing date where the period cannot be established (79 filings). Release cutoff: period of report on or before 2025-09-30.

## 3. SEC source provenance
Primary documents retrieved from SEC EDGAR during the certified run; each ledger row carries the document URL, payload byte length and SHA-256. Payload hashes are over the decoded bytes Fetch exposes (all SEC responses were gzip-encoded; Content-Length is telemetry only).

## 4. Retrieval integrity and the no-disclosure double-fetch rule
- Final NO_RELEVANT_DISCLOSURE filings: 8,056; with valid double-fetch proof (both HTTP 200, both network, both no Item 703, identical SHA-256 and byte length): 8,056; violations: 0.
- RETRIEVAL_INCONSISTENT outcomes: 0.
- RETRIEVAL_FAILURE filings: 1 (Ball Corp. 10-Q/A 2007-10-17, PRIMARY_FETCH_ERROR).
- Fetches needing a retry: 0; rejected cache entries: 0.
- Known transient-retrieval controls: Pall Corp. 2008 PROCESSED (4 facts); Aon PLC 2007 PROCESSED (3 facts); Wynn 2022 PROCESSED (3 facts); PMI 2016 PROCESSED (3 facts).

## 5. Fail-closed philosophy and REVIEW semantics
A fact is released only if its filing is PROCESSED and no review rule fired; REVIEW never means a fact is known to be wrong, only that it could not be shown to be safe. Withheld facts are retained internally with their reasons and are not shipped. Filing-level REVIEW releases zero facts. See methodology.md section 5.

## 6. Accession-level quarantine
13 exact filings, each adjudicated from its own saved source table (`adjudicated_unsafe_tabular_filings.json`); all 13 are REVIEW with zero facts:
- Constellation Brands, Inc. `0000016918:0000016918-21-000217` - REVIEW, 0 facts
- XTO Energy `0000868809:0001193125-05-216982` - REVIEW, 0 facts
- United Rentals, Inc. `0001067701:0001067701-20-000008` - REVIEW, 0 facts
- United Rentals, Inc. `0001067701:0001067701-22-000008` - REVIEW, 0 facts
- Norwegian Cruise Line Holdings, Ltd. `0001513761:0001558370-19-007736` - REVIEW, 0 facts
- Merck & Co., Inc. `0000310158:0000310158-19-000037` - REVIEW, 0 facts
- Procter & Gamble Co. `0000080424:0000080424-15-000070` - REVIEW, 0 facts
- Procter & Gamble Co. `0000080424:0000080424-17-000047` - REVIEW, 0 facts
- Clorox Co. `0000021076:0001359948-16-000048` - REVIEW, 0 facts
- Clorox Co. `0000021076:0000021076-18-000004` - REVIEW, 0 facts
- Newell Brands, Inc. `0000814453:0001193125-11-052372` - REVIEW, 0 facts
- Union Pacific Corp. `0000100885:0001193125-08-215351` - REVIEW, 0 facts
- DeVry, Inc. `0000730464:0000950123-10-100754` - REVIEW, 0 facts
Same-CIK non-quarantined filings are unaffected (no non-listed filing carries the quarantine reason).

## 7. Release-safety invariants (clean output)
| Check | Result |
| --- | --- |
| Negative value in a released (a)-(d) | 0 (of 532 manufactured negative facts, all withheld) |
| Explicit multi-period aggregate released as a month | 0 |
| Price-shaped (c) with (b) empty released | 0 |
| Whole number ≥ 10,000 released as an average price | 0 |
| Standalone "(n)" footnote marker in any released field | 0 |

## 8. Known-defect controls
The controls below are regression tests for previously observed extraction failure modes; they are not investment conclusions or claims about the issuers themselves.

- PASS - no-negative-in-clean-(a)-(d)
- PASS - no-standalone-(n)-marker-in-any-clean-field (M-A / M-B signature)
- PASS - Comerica, Inc. 2016 PERMUTED matches merged R4 rowsAfter
- PASS - Comerica, Inc. 2018 PERMUTED matches merged R4 rowsAfter
- PASS - Union Pacific Corp. 2012 CANONICAL_CAPTIONS_REFUSED_DATA matches merged R4 rowsAfter
- PASS - Union Pacific 2012 remains valid (same-CIK control, unchanged)
- PASS - Teradata 2010 corruption remains fail-closed
- PASS - Devon commodity-table false positive absent
- PASS - Union Pacific 2008 remains quarantined
- PASS - PepsiCo negatives remain REVIEW, not rewritten
- PASS - Ecolab parenthesized prices remain REVIEW
- PASS - no multi-month period ships clean as a single normalized month
- PASS - no per-share price shipped clean in (c) with (b) empty
- PASS - no whole number >= 10,000 shipped clean as an average price (b)
- PASS - DeVry 2010: primary Item 703 table not replaced by the secondary table
- PASS - no known M-A / M-B case ships a clean fact

## 9. Counts
| Disposition | Previous run 37727345851 | Certified run 37794101419 |
| --- | --- | --- |
| PROCESSED | 29,446 | 29,445 |
| OUT_OF_SCOPE | 24,208 | 24,209 |
| NO_RELEVANT_DISCLOSURE | 8,056 | 8,056 |
| UNADJUDICATED_NARRATIVE_DISCLOSURE | 2,969 | 2,969 |
| REVIEW | 2,165 | 2,166 |
| EXPLICIT_NO_PURCHASE | 753 | 753 |
| SCHEMA_GAP | 7 | 7 |
| RETRIEVAL_FAILURE | 1 | 1 |

| Facts | Previous run | Certified run |
| --- | --- | --- |
| Manufactured | 107,339 | 107,335 |
| Released (clean) | 70,018 | 69,161 |
| Withheld (REVIEW) | 37,321 | 38,174 |

## 10. Known unsupported structures
Comparative-period column groups (S4), missing/split/extra SEC columns (S2/S3), fixed-width text tables, standalone footnote markers occupying a value slot (R2), multiple Item 703 tables per filing (only the first safely mapped table is extracted), narrative-only disclosures. All are routed to REVIEW or recorded as non-tabular dispositions; none is guessed. See LIMITATIONS.md.

## 11. Release cutoff
Period of report on or before 2025-09-30 (Historical Cohort Release 1.1 cutoff); documents as retrieved from SEC EDGAR during run 37794101419.

## 12. Buyer-package presentation (packaging amendment, same certified run)
The package was rebuilt from the same run 37794101419 without any change to facts, classifications, dispositions or released/withheld membership:
- `period_of_report` is the verified effective period (blank for 79 unresolved filings and 1 never-retrieved filing); `sec_metadata_period_of_report` and `period_of_report_verification_status` were added to both buyer files. Status counts:
| Value | Filings | Meaning |
| --- | --- | --- |
| `AGREE` | 42,364 | The SEC metadata period of report equals the period stated on the filing's cover page. period_of_report = that date. |
| `UNPARSED_METADATA_PLAUSIBLE` | 766 | The cover page could not be parsed; the SEC metadata date is plausible for the form and filing date and is used. |
| `COVER_OVERRIDE` | 167 | The SEC metadata date is implausible and the cover-page period is plausible; period_of_report = the cover-page date (the metadata date is kept in sec_metadata_period_of_report). |
| `CONFLICT_UNRESOLVED` | 58 | Metadata and cover page disagree and neither can be preferred. period_of_report is BLANK. |
| `UNVERIFIED_IMPLAUSIBLE` | 21 | The cover page could not be parsed and the metadata date is implausible for the filing. period_of_report is BLANK. |
| `AGREE_WITHIN_3D` | 20 | Metadata and cover page differ by 3 days or less; the metadata date is used. |
| (blank) | 1 | Verification never ran because the document could not be retrieved (RETRIEVAL_FAILURE). period_of_report is BLANK. |
- Buyer-facing `disposition_reason` text no longer cites internal repository paths or function names (reason codes and evidence retained).
- `LICENSE.txt` added.

## 13. Buyer-documentation amendment (same certified run)
Definitions for the interpretation fields, a sample walkthrough (`sample/README.md`), amendment and column-(d) usage notes, a narrower internal-API clause in `LICENSE.txt`, and a buyer preface in the quarantine record. No fact, classification, disposition or released/withheld membership changed.