The $200 Fine

• Key findings
• 12.5% of disclosures are filed late (12,559 of 100,875), across 336 members. The median gap, though, is 28 days — most file on time.
• 2,397 trades were disclosed more than a year after they happened — about 19% of all late filings.
• The worst high-volume record: Rep. Thomas Suozzi (D-NY) — 86.5% late, an average 675-day gap.
• Compliance is achievable: Rep. Ro Khanna (D-CA) filed 0.9% of 24,585 trades late; Pelosi, 0%.
• The penalty for any late filing — one day or five years — is a $200 fee, often waived. Prosecutions under the Act since 2012: zero.

1. Introduction: the law with a deadline

In 2012, after reporting revealed members of Congress trading on non-public information, Congress passed the Stop Trading on Congressional Knowledge Act — the STOCK Act — by overwhelming, bipartisan margins. The law's central mechanism is sunlight: a member must publicly disclose each securities transaction within 45 days, on a Periodic Transaction Report. The theory is that timely disclosure deters abuse, because a trade made on an information advantage cannot stay hidden long enough to be useful or unaccountable.

Fourteen years of filings let us test whether the mechanism works. The research question is deliberately narrow and empirical: how often is the 45-day rule actually met, how late are the misses, who misses, and what happens when they do? The answer has two halves that are usually collapsed into one. The disclosure requirement largely works — most trades are reported on time. The enforcement regime behind it barely exists. The gap between those two is the subject of this paper.

2. Data and methodology

We analyze every congressional stock-trade disclosure GovGreed tracks with a computable filing gap — the number of days between the transaction date and the date the disclosure was filed. After deduplication (the raw feed double-ingests a large share of filings), this yields 100,875 transactions by 336 members, spanning 2012–2026. A disclosure is counted “late” when its gap exceeds 45 days, the statutory deadline. We report the rate, the distribution of how late the late filings are, and a per-member leaderboard. The method shared across this series — sources, mapping, and verification — is documented at GovGreed Research.

Two cautions. First, a late filing is a compliance fact, not proof of insider trading; the overwhelming majority of trades, late or not, are ordinary. Second, the extreme tail of the gap distribution contains a small number of parsing artifacts (a 2024 filing mis-stamped with a 2013 trade date, for example), so we anchor claims on rates and averages over members with enough trades to be stable, not on the single largest gap. All figures were re-derived live on June 30, 2026.

3. The compliance record

3.1  Most members file on time

The honest headline is that the law mostly works. Of 100,875 disclosures, 88,316 (87.5%) were filed within the 45-day window, and the median filing gap is 28 days — comfortably inside the deadline. The average gap is 49 days, pulled above the deadline only by a heavy right tail. Compliance is the norm; the story is the exceptions, because the exceptions are where the rule is supposed to bite and doesn't.

3.2  How late the late ones are

Among the 12,559 late filings, lateness is not a near-miss phenomenon. About half (6,371) land in the 46–90-day band — weeks past due. But the rest stretch much further: 1,749 took three to six months, 2,042 took six months to a year, and 2,397 took more than a year. Nearly one in five late filings disclosed a trade only after a full year had passed — long after any information edge had resolved and any market reaction had played out.

The 12,559 disclosures filed past the 45-day deadline, by gap length. On-time filings (88,316) excluded to show the tail. Verified June 30, 2026.

4. The worst offenders

Lateness concentrates. Ranking members with at least 50 trades by the share filed late produces a list that crosses both parties — and it is not the household names. At the top are members whose offices appear to treat the deadline as optional: several file the large majority of their trades late, with average gaps measured in hundreds of days. The most extreme high-volume case, and the one hardest to attribute to a one-off, is Rep. Thomas Suozzi.

Member	Party	St.	Trades	% late	Avg gap
SBSheri Biggs	R	SC	80	97.5%	196 d
JLJulia Letlow	R	LA	196	94.4%	285 d
TSThomas Suozzi	D	NY	628	86.5%	675 d
DJDavid P. Joyce	R	OH	133	86.5%	336 d
GPGary J. Palmer	R	AL	233	85.8%	204 d
RARick W. Allen	R	GA	218	67.9%	767 d
RMRoger Marshall	R	KS	149	65.8%	272 d
BDByron Donalds	R	FL	203	63.5%	539 d
KCKatherine M. Clark	D	MA	490	62.2%	105 d

Deduplicated disclosures, members with ≥50 trades, ranked by share filed past the 45-day deadline. Bipartisan: Democrats and Republicans both appear. Katherine Clark is the House Minority Whip. Verified June 30, 2026. Look up any member on the Congress leaderboard.

5. The deep-dive: a portfolio disclosed two years late

Rep. Thomas Suozzi (D-NY) is the clearest case because the pattern is too large and too consistent to be a clerical accident. Of his 628 disclosed trades, 543 — 86.5% — were filed late, and the average gap across all of them is 675 days. The worst single filing in his record reached 1,839 days — slightly more than five years between the trade and its disclosure.

The point is not that any one Suozzi trade was improper — we make no such claim, and the trades may well be passive or manager-directed. The point is what the law permits: a member can disclose hundreds of trades years after the fact, defeating the entire purpose of a 45-day rule, and face no consequence beyond a fee smaller than the commission on a single trade. Suozzi is the extreme, but Table 1 shows he is not alone — and the members above him on the list traded less, not more honestly.

6. Compliance is possible — which is the problem

The counter-case matters, because it removes every excuse. If timely disclosure of a large, active portfolio were genuinely impractical, the worst records would be the busiest traders. The opposite is true. Rep. Ro Khanna (D-CA) is the most active trader in Congress — 24,585 disclosed trades — and files just 0.9% of them late, on a 26-day average. Nancy Pelosi, the single most scrutinized name in congressional trading, shows 0% late. Even Michael McCaul — whose 16,000+ trades through managed accounts produce thousands of late filings in raw counts — still files on time about four times out of five.

The lesson, stated carefully in marketing-voice terms: Pelosi's perfect record is a footnote, not a headline — but it is a load-bearing footnote. It proves the deadline is met by those who choose to meet it. The 12.5% who don't are not defeated by logistics; they are unbothered by the consequence. Which brings us to the consequence.

7. The penalty, and the enforcement gap

Here is the entire downside of filing a congressional stock trade five years late: a $200 fee. It is flat — there is no escalation for repeat or extreme lateness — and it can be waived by the House or Senate ethics committees, which routinely grant waivers for “inadvertent” errors. There is no public ledger of who has paid it. And in the fourteen years since the STOCK Act passed, no member of Congress has been criminally prosecuted under it. The deterrent the law was supposed to create — that a hidden, advantaged trade would be exposed and punished — has the exposure half and not the punishment half.

This is why the disclosure-versus-enforcement distinction is the whole story. The disclosure mechanism is real: file counts are public, gaps are computable, and a researcher can produce Table 1 at all because the data exists. The enforcement mechanism is a $200 line item a member can ignore. A rule that is measured but not enforced converts into its opposite: a paper trail that documents non-compliance in detail while doing nothing about it.

8. Discussion

The compliance data resolve a common confusion. The problem with congressional stock trading is frequently framed as “they trade on inside information” — a claim that is hard to prove transaction by transaction and easy to deny. The compliance record reframes it as something simpler and provable: the one rule that is supposed to keep the system honest is optional in practice. Most members follow it; a measurable minority do not; and the law is indifferent to which group a member joins.

That indifference is the policy choice worth naming. A late-filing regime with a flat, waivable $200 fee and no prosecutions is not a failed enforcement system — it is a system designed to disclose, not to deter. The reform proposals that recur in Congress (a full ban on individual-stock ownership by members, or at minimum graduated penalties and mandatory blind trusts) are, in this framing, simply proposals to make the enforcement half match the disclosure half. Whether to do so is a question for Congress. What the data settle is that the current answer is “no.”

9. Limitations and caveats

• Late ≠ insider trading. A missed deadline is a compliance failure, not evidence that a trade exploited non-public information. This paper measures timeliness, nothing more.
• Holdings are often manager-directed. Many high-volume filers trade through managed or blind-style accounts; lateness can reflect a filing process, not personal intent. We name patterns, not motives.
• The extreme tail has artifacts. A small number of records carry impossible gaps (a trade date years before a filing) that are parsing errors, not real decade-long delays. We therefore lead with rates and averages over members with ≥50 trades, not the single maximum gap.
• Coverage is the tracked, deduplicated set. 100,875 transactions with a computable gap, after removing the raw feed's duplicate ingestion. Members who do not trade individual stocks do not appear.
• The $200 fee and “zero prosecutions” are matters of public record, not derived from our database; see the references.

10. Conclusion

The STOCK Act is, on the evidence, a successful disclosure law and a non-existent enforcement law. Most members file on time; the data prove it can be done even for the busiest portfolios. But when a member doesn't — when 86% of a portfolio surfaces an average of 675 days late — the system's response is a $200 fee it may not even collect. GovGreed did not need a leak to find any of this; the lateness is disclosed in the same filings the law requires. The deadline is real. The consequence is the $200 fine. The distance between them is the policy.

Frequently asked

References & data sources

1. STOCK Act disclosures — congressional Periodic Transaction Reports (House & Senate), as tracked in GovGreed's Congress database; per-member history on any member page.
2. The disclosure law — The STOCK Act, explained: the 45-day rule, the $200 fee, and the enforcement record.
3. Methodology — GovGreed Research: sources & methods: deduplication, gap computation, and the verification protocol shared across the series.
4. Companion papers — Who the U.S. Government Actually Pays (GGR-WP-2026-01) · The President's Checkbook (GGR-WP-2026-02).
5. Image credit (public domain): The United States Capitol, west front — public domain via Wikimedia Commons.

Keep pulling the thread

Not financial advice. All data from public federal disclosures.