What Makes a Peer? Valuation-Anchored Similarity in Private Markets

Shadow trading -- trading in a peer firm's securities on the basis of material nonpublic information (MNPI) about an "economically linked" company -- is a novel and contested theory of insider trading liability, first prosecuted in SEC v. Panuwat (2023). Enforcing it requires identifying economically linked firms ex ante, a determination the SEC makes only after the fact using mass market surveillance infrastructure. We ask whether NLP can do what the SEC's theory presumes insiders already know: identify peer firms ex ante from publicly mandated disclosures. Using a two-stage LLM pipeline applied to Item 7 (Management's Discussion and Analysis) sections of SEC 10-K filings, we score semantic similarity across 30 M&A events spanning five industries and relate similarity to announcement-day abnormal stock returns. On the Panuwat fact pattern itself the pipeline recovers Incyte among the closest peers, a sanity check on the one case with a known outcome. Across the full dataset, however, we find no association: pooling 217 peer observations, the within-event rank correlation between similarity and abnormal return is +0.07 (permutation p = 0.37), and the mean per-event Spearman correlation is +0.05 with a 95% confidence interval of [-0.08, +0.18] -- narrow enough to exclude any moderate relationship rather than merely failing to detect one. A case-level reading agrees: 14 of 30 events support the hypothesis, 12 contradict it, and 4 are ambiguous. We also find that Incyte fell outside the standard $2B-$10B mid-cap band on the day before the announcement, complicating the "mid-cap oncology" category the SEC invoked. These results are exploratory and bound to this pipeline, corpus, and return measure, but they put pressure on the empirical premise of shadow trading enforcement and bear on constitutional questions surrounding the SEC's financial surveillance infrastructure.

Task-agnostic tabular embeddings are increasingly used for similarity search in real-world business systems such as Product Lifecycle Management (PLM). However, leading embedding approaches are optimized primarily for prediction tasks - not for producing human preference aligned similarity rankings. We argue that standard downstream metrics are insufficient to fully assess embedding trustworthiness for similarity search and that human preference aligned evaluation is a necessary and currently missing component. We present a concrete evaluation procedure and illustrate the problem through a PLM use case.

Financial models combine public disclosures with analyst assumptions to produce forecasts and valuations. While some components can be checked mechanically, forecasts, discount rates, and target prices often admit multiple reasonable answers. Existing benchmarks nevertheless tend to grade such outputs against a single expert reference. Using independently built analyst models for the same companies, we find that across 108 directed pairs covering 65 companies, the median single-reference score is 0.33, 92.6% score below 0.70, and no same-vintage pair agrees on implied price within 10%. Point-tolerance grading can therefore penalize disagreement already present among professionals. We introduce GAUGE, a benchmark for evaluating agent-built valuation models against observed analyst practice rather than a single point answer. GAUGE uses 1,001 vendor-classified analyst workbooks and a 196-task evaluation set, with a three-layer observed-practice envelope, 56 auditable facets, eight validity gates, and deterministic structural checks. We validate the benchmark with a 55-participant known-groups study, company-grouped cross-fitting, and judge-stability audits. On the failure-aware score $φ_0$, senior analysts average 88.3, juniors 66.0, and finance students 43.2. Across 24 agents and 1,011 scored generations, the best agent scores 53.4, above the student mean but below every senior and most juniors. It passes 93% of mechanical facets and 78% of judgment facets, with a fleet-median gap of 26 points. Current agents are substantially stronger at model construction than valuation judgment. We release the methodology, a gated de-identified data tier, a controlled training split, a versioned 48-task evaluation core, and a withheld refresh pool.