Davis Polk partner Joe Hall authored “Agentic AI and securities law: Evolving risk disclosures” in Law360. The fourth article in a five-part series, this piece examines the strain agentic AI poses for the current U.S. disclosure regime. Joe notes, “The question now is whether [the disclosure regime] can accommodate decision-making systems whose behavior is not fully predictable to those who deploy them.”

In the article, Joe discusses issues with Management Discussion and Analysis (MD&A), risk factor disclosure, system level disclosure, the question of materiality, and practical implications for issuers. 

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