Only 23 of 405 S&P 500 Firms Had a Real Insider Buy in 2024

The problem: Every January, the financial press runs the same headline — "Insiders are buying!" — usually backed by an OpenInsider screenshot of three CEOs and a generic line about vote of confidence. The framing falls apart at scale. When you actually pull every Form 4 open-market purchase above $1 million across the S&P 500 for a full calendar year and filter to named officers and directors, the picture isn't insiders are buying. It's that the overwhelming majority of S&P 500 issuers had nobody on the inside step up and write a real cheque last year, two names accounted for 63% of the total dollar volume, and the most-watched megacap CEOs in America bought a combined zero. This post is what the 2024 honor roll actually looks like.

This is a documentary audit of S&P 500 open-market officer and director purchases ≥$1M during calendar year 2024, sourced from SEC EDGAR Form 4 filings. Every dollar figure is deduplicated against Form 4/A amendments and links back to the underlying filing index. The 5.7% scarcity figure is real, the megacap absence is real, and the framing the financial press usually slaps on top is almost always wrong about what the cohort shows.

What is the S&P 500 officer-buy honor roll? A complete list of S&P 500 companies that had at least one named officer or director buy at least $1 million of their own stock on the open market during calendar year 2024, as disclosed on SEC Form 4 within the regulatory filing window.

Why it matters: Open-market officer purchases above $1 million are the single hardest signal an insider can send. They're voluntary, expose personal capital, are subject to short-swing profit rules, and unlike option exercises or grants, they require the insider to write a real cheque. Aggregating them across the full S&P 500 is the cleanest available read on which boards and management teams actually put their own money behind their stock last year.

Use it when: You're researching insider-cluster patterns at a specific issuer, building a watchlist of management teams that have skin in the game, comparing 2024 buying activity against historical baselines, or auditing the gap between insiders are buying press narratives and what Form 4 filings actually show.

Key findings

• Of ~405 S&P 500 issuers tested, only 23 (5.7%) had a named officer or director buy ≥$1M of their own stock on the open market in 2024. The remaining 94.3% had zero such buys.
• Two names — Ariel Emanuel at TKO and Charles Ergen at SATS — account for $168.3M of the $267.4M cohort total (63%). Both are also 10%+ beneficial owners, so part of that volume is portfolio construction, not pure executive-confidence signalling.
• The Mag 7 plus Berkshire, JPM, UnitedHealth, Visa, Walmart and the rest of the top US megacaps had a combined zero ≥$1M open-market officer/director buys in 2024. ExxonMobil's Maria Dreyfus was the only ≥$1M buyer at any company in the audit's top-20 megacap list.
• The Keurig Dr Pepper March 5, 2024 cluster is the cleanest signal of the year. CEO Bob Gamgort, JAB chairman Peter Harf and JAB partner Olivier Goudet each bought exactly $4,999,991 on the same day, with CFO Sudhanshu Priyadarshi adding $2.5M.
• Rakesh Gangwal's $61.7M Southwest Airlines purchase across 30 single-day transactions on September 30, 2024 is the largest pure-director buy in the cohort — directly tied to Elliott Management's settlement that put him on the board.

Problems this solves

• How to find every S&P 500 officer or director that bought ≥$1M of their own stock in 2024
• How to separate pure-officer buys from 10% beneficial owner activity in Form 4 data
• How to detect coordinated same-day insider cluster buys across an issuer
• How to deduplicate Form 4 originals against Form 4/A amendments at scale
• How to audit the insiders are buying press narrative against the actual filing trail
• How to score whether a megacap had genuine insider conviction in a given year

In this article

The 23-name leaderboard · 10%-holder caveat · Pure-officer top buys · KDP March 5 cluster · Gangwal/Southwest · Megacap absence · Sector breakdown · Methodology · FAQ

Quick answer

• What the audit measures: ≥$1M named-person officer or director open-market purchases at S&P 500 issuers, calendar year 2024, sourced from SEC EDGAR Form 4.
• Cohort size after filters: 23 issuers from ~405 tested, 84 deduped buys, $267.4M total dollar volume.
• Headline scarcity: 5.7% of tested issuers had any qualifying buy. Excluding 10%-holder cases drops it to 5.4%.
• Most striking single-day signal: Keurig Dr Pepper March 5, 2024 — three insiders, identical $4,999,991 buys, plus CFO at $2.5M.
• Main tradeoff: ~98 of 503 tickers were unreached when the audit hit its runtime budget. The 23-issuer figure is a floor, not a ceiling.

Compact examples

What is an open-market officer or director purchase?

Definition (short version): An open-market officer or director purchase is a Form 4-disclosed transaction in which a corporate insider buys their own company's stock on a public exchange using personal funds, reported under transaction code "P" rather than option-exercise, grant, or gift codes.

The signal sits in the difference between code P and everything else. Officers receive equity through grants, exercises, restricted stock vesting, and 10b5-1 sales — none of which require them to write a personal cheque or take on price risk. A code-P open-market buy means the insider went into the market, paid the prevailing price, and now has unhedged exposure to their own company's share-price drift. There are roughly four flavours of insider buying tracked by SEC EDGAR Form 4 filings: pure code-P open-market purchases, option exercises that result in retained shares, indirect purchases through trusts and family vehicles, and tender-offer participation. This audit is scoped to the first one.

Also known as: insider open-market buy, code-P transaction, Form 4 purchase, executive bid, director cash-buy, officer-confidence purchase.

Why officer-buy scarcity matters

The scarcity ratio is the headline most insider-buying coverage glosses over. When 94.3% of tested issuers had zero ≥$1M named-person buys in 2024, insiders are buying is structurally the wrong sentence. The accurate sentence is: the overwhelming majority of S&P 500 management teams and boards did not put personal capital into their own stock at material scale last year. That holds even after restricting to ≥$1M (a meaningful threshold for senior-officer compensation but not punishing for board members) and even before excluding the two 10%-holder cases.

The pattern matters because the insider buying = bullish signal heuristic relies on insider buys being a populated set. When the set is sparse, every individual buy carries more weight, and absence becomes an evidentiary signal in its own right. The Mag 7 zero — discussed below — is only legible against the scarcity baseline.

The 23-issuer leaderboard

Sorted by deduped 2024 total buy value. Every row is named officers and directors only — no institutional Form 4 filers, no corporate vehicles, no estates.

That's the entire honor roll. Twenty-three names. Below the $1M threshold the list grows considerably, but $1M is the line where a buy stops being a token gesture and starts being a meaningful personal allocation for almost every officer and director on this list.

The 10 percent holder caveat

This is the line most blog posts will skip. Two of the 23 issuers — TKO and SATS — account for $168.3M of the $267.4M cohort total, or 63% of the dollar volume. Both buyers are also 10%-plus beneficial owners of their issuer:

• Ariel Emanuel at TKO Group Holdings — Endeavor's CEO sits on the TKO board and controls a substantial economic interest through Endeavor's stake. His 15 buys between December 11 and December 17, 2024 totalled $124.8M.
• Charles W. Ergen at EchoStar (SATS) — founder and chairman, long-running 10%+ beneficial owner. A single $43.5M buy on November 12, 2024.

When a CEO is also a controlling shareholder, an open-market buy is a hybrid signal. Some of it is executive conviction. Some of it is portfolio rebalancing inside a much larger personal position. Treating these the same as a pure-officer buy by a non-controlling executive overstates the vote of confidence read.

Stripping those two out, the cohort drops to 22 issuers and roughly $99.1M of pure-officer-only deduped buy value — about 37% of the headline number. The set of issuers where a non-controlling officer or director put real personal capital on the line in 2024 is meaningfully smaller than the headline 23 suggests.

Pure-officer top buys

After excluding 10%-holder buys, the leaderboard's centre of gravity moves to a small set of director-led purchases at relatively boring industrials and consumer names:

Three patterns jump out.

Director-led, not CEO-led. The largest pure-officer buys (Gangwal, Fribourg, Knight, Salem, Dreyfus) are all board members rather than operating executives. CEO buying at this scale is rare in 2024 outside the KDP cluster, the FOX situation, and a handful of one-off mid-cap names.

Private-equity adjacent. Knight (RoundTable Healthcare Partners), Fribourg (Continental Grain CEO), Salem (Providence Equity co-founder), Goudet (JAB Holding) — these are board members with deep personal balance sheets and a professional history of taking concentrated positions. Their buys are still meaningful, but they're being made by people for whom $5M-$25M of single-issuer exposure isn't a stretch.

Cluster events at MSCI and KDP. The KDP March 5 cluster is the standout (covered below), but MSCI also shows a same-week pattern between CEO Henry Fernandez and COO Baer Pettit — three buys totalling $6.6M concentrated in one window. Coordinated same-window buying by C-suite peers is the kind of pattern that's only legible when you audit the full cohort.

The Keurig Dr Pepper March 5 cluster

This is the most striking single-day signal in the entire 2024 cohort, and it's exactly the kind of pattern you'd never spot eyeballing OpenInsider one ticker at a time.

On March 5, 2024, three Keurig Dr Pepper insiders bought exactly $4,999,991 of stock — the same amount, on the same day:

• Bob Gamgort — CEO at the time
• Peter Harf — Chairman of JAB Holding Company, KDP's largest shareholder
• Olivier Goudet — JAB Holding partner and KDP director

Plus CFO Sudhanshu Priyadarshi added $2.5M the same day. Total KDP March 5 cluster: $17.5M across four senior insiders, three at identical-to-the-cent dollar amounts.

When three insiders independently choose the same date and the same dollar value down to the unit, it's not coincidence and it's not coordinated illegally. It's a pre-arranged board-level vote of confidence — typically the result of management and large-shareholder representatives agreeing to take simultaneous positions ahead of, or in response to, a strategic event. The dollar value pegged at $4,999,991 (one penny under $5M) is the giveaway: someone calculated the exact share count that would land just below a round-number reporting threshold, and three insiders executed on the same calculation.

You can dig into the underlying filings on SEC EDGAR's Keurig Dr Pepper insider transaction history. The March 5 entries are clustered together at the top of the 2024 filings.

The reason this matters for the audit: it's a four-buy cluster, on a single day, hitting a CEO + CFO + two large-shareholder directors. That's the highest-conviction insider pattern publicly available, and it shows up in exactly one S&P 500 issuer in 2024. One in roughly 405.

Gangwal Southwest and the Elliott settlement

If KDP is the cluster signal of the year, Rakesh Gangwal at Southwest Airlines is the personality story. Gangwal — the IndiGo founder and former US Airways CEO, one of the most experienced operators in commercial aviation — joined Southwest's board on September 9, 2024 as part of Elliott Management's activist settlement with Southwest. Twenty-one days later, on September 30, 2024, he bought $61.7 million of LUV stock across 30 separate transactions.

This is the largest pure-director buy in the entire S&P 500 cohort for 2024. It's also the highest-conviction insider purchase Southwest has seen in over a decade. Five things are happening here at once:

• A newly-installed activist-aligned director taking maximum public exposure to the turnaround thesis on day one
• The transaction structured as 30 individual buys in a single day — almost certainly a function of legging into a position around volume-weighted average price rather than a single cross
• $61.7M of personal capital being deployed against a stock that had underperformed the airline sector for years before the Elliott campaign
• A director with operating credibility — not a financial-only board member — putting his name on the public filing
• Zero hedging activity disclosed in the surrounding period, leaving the position fully exposed to LUV's drift

The contrast with the rest of the airline sector is sharp. No other S&P 500-listed US airline had a ≥$1M named officer or director buy in 2024. Gangwal's number is the entire airline-sector officer-buy cohort.

The megacap zero-buy finding

The single most-quoted finding in this audit is going to be this one. Of the 14-20 most-valuable S&P 500 names — collectively worth over $14 trillion — exactly one had a named officer or director buy ≥$1M of their own stock on the open market in 2024:

The Mag 7 collectively had zero. The biggest banks had zero (JPM, BAC, WFC, C, GS, MS — all empty). Big Pharma had zero (LLY, JNJ, MRK, PFE, ABBV — all empty). Walmart, Home Depot, Procter & Gamble, Costco — all empty.

Maria Dreyfus's $2M buy at ExxonMobil — she's an Apollo strategic partner who joined the Exxon board in 2024 — is the entire ≥$1M named-person buy activity at the top of the index. One $2M trade. Across the most-watched 18 names in the United States stock market.

The honest reading is not that megacap insiders think their stocks are overpriced. It's that megacap executive compensation is so heavily skewed toward grants, options, and 10b5-1 plans that there is essentially no scenario under which the median Mag 7 executive needs to buy stock on the open market — they receive far more equity than they could ever choose to acquire voluntarily. Open-market buying by a megacap CEO would be a strange and conspicuous act. The absence is structural, not bearish.

But it is also evidence against the insiders are buying press narrative as applied to the broad market. Whatever insiders are doing in 2024, they are not, in aggregate, putting personal capital into the stocks at the top of the S&P 500.

Sector concentration

Where the 23 honor-roll buys actually live:

The cohort skews industrial, financial-services, and consumer — exactly the sectors where insider-buying signals have historically had the most predictive power, and where executive compensation packages contain less equity dilution than at megacap tech. Healthcare insurance (CNC) is the entire healthcare contribution. Big Pharma is empty. Big Tech is empty (mid-cap tech contributes three names, none megacap). Big banks are empty.

If you treat the 23 names as a watchlist, you're effectively looking at a list of S&P 500 companies whose boards or management put real money down in 2024. That's an unusual filter, and it's a more interesting starting point than "stocks insiders are buying" lists typically produce.

Mini case study — what the audit caught vs eyeballing one ticker

Before this audit, here's what was visible from the standard insider-tracking workflow at the time:

Before: financial press coverage in mid-March 2024 reported "Keurig Dr Pepper CEO Bob Gamgort buys $5M of KDP stock." Source: a single OpenInsider notification triggered by the Form 4 filing.

After: auditing the full S&P 500 cohort surfaced the actual signal — Gamgort, Harf, Goudet, and Priyadarshi all bought on the same day, with three of the four hitting identical $4,999,991 amounts. The cluster as a coordinated event is roughly 4x more informative than any single buy in isolation, because three independent decisions converging on the same date and amount changes the base-rate probability of the signal being noise.

Same Form 4 filings. Same SEC EDGAR data. Different conclusion. The difference is the audit scope — running the query across all 503 tickers in one batch and grouping by [ticker, date] surfaces clusters that are invisible in the per-ticker view.

Best practices for auditing officer-buy data at scale

1. Always dedupe Form 4 originals against Form 4/A amendments before counting. SEC EDGAR returns both. Match on [ticker, insider, date, value] to collapse 4+4/A pairs. Without dedupe, the raw count overstates by 60-70%.
2. Filter buyer names against an institutional-suffix regex. INC|CORP|LP|LLC|FUND|CAPITAL|TRUST|HOLDINGS|MANAGEMENT|PARTNERS|VENTURES covers most of the corporate filers that would otherwise pollute the natural-person bucket.
3. Split 10% beneficial owners out as a separate layer. When a CEO is also a controlling shareholder, the buy is a hybrid signal. Reporting the headline cohort number with and without 10%-holder cases is the honest framing.
4. Use event date, not filing date, for the calendar-year cut. Form 4 filings have a 48-hour window. Q4 events filed in Q1 of the following year still belong to the prior calendar year for audit purposes.
5. Group by [ticker, date] to surface cluster events. Three insiders on the same day with similar amounts is a structurally different signal than three insiders across three different days — only the grouped view exposes it.
6. Track coverage explicitly. When a long-running batch hits a runtime budget, the unreached tickers matter for floor/ceiling framing. Without an explicit processedTickers[] list, you're inferring coverage from absence, which is ambiguous.
7. Cross-reference against the issuer's Q4 earnings calendar. A cluster buy 5-10 days before an earnings call carries different implications than one in a quiet window.

Common mistakes when reading insider-buying data

1. Conflating option exercises with open-market buys. SEC Form 4 covers both. Code "P" is the open-market purchase signal. Code "M" is option exercise. Press coverage routinely reports the latter as the former.
2. Counting every Form 4/A amendment as a new buy. The amendment is a correction to the same underlying transaction, not a second purchase.
3. Treating 10%-holder buys as executive-confidence signals. A controlling shareholder rebalancing a position is structurally different from a non-controlling officer writing a personal cheque.
4. Reading megacap absence as bearish. Megacap executives receive equity primarily through grants. Open-market buying by a Mag 7 CEO would be a strange and conspicuous act, not a baseline behaviour.
5. Stopping at one ticker. Same-day cluster patterns across multiple insiders at a single issuer are only visible when you audit the full cohort. Per-ticker views miss them.
6. Ignoring the floor/ceiling distinction in truncated audits. When ~98 of 503 tickers were unreached, the 23-issuer figure is a floor. The actual 2024 honor-roll size could be 27-30 issuers.

What are the alternatives to a full S&P 500 Form 4 audit?

There are essentially four ways people approach insider-buying analysis. Each has a different tradeoff profile:

Each approach has tradeoffs in cost, granularity, dedupe quality, and ability to detect cluster signals. The right choice depends on whether you're tracking one ticker or a cohort, whether you need cluster detection, whether you can absorb per-seat licensing, and whether you have the engineering bandwidth to maintain a full-text EDGAR pipeline yourself.

Data and tooling notes are based on publicly available information as of May 2026 and may change.

Implementation checklist

If you want to reproduce or extend this audit:

1. Pull the current S&P 500 constituent list (datasets/s-and-p-500-companies on GitHub is the standard public source) and snapshot the date.
2. Configure your Form 4 query with transactionType: "purchase", transactionDateFrom: "2024-01-01", transactionDateTo: "2024-12-31" on event date, and a filing window that extends into Q1 2025 to capture the regulatory tail.
3. Set minTransactionValue: 1000000 to land on the same threshold this audit uses.
4. Use queryMatchMode: "exact" to cut down out-of-cohort hits, but expect a small number of edge cases (this audit caught 5 leaks across BTSG, HARP, KYTX and a KKR-vehicle entry).
5. Allocate at least 7200 seconds of runtime budget for a full S&P 500 batch — SEC EDGAR rate-limits, and you will hit the deadline before all 503 tickers process.
6. Dedupe Form 4 originals against Form 4/A amendments on [ticker, insider, date, value] before counting.
7. Filter buyer names against the institutional-suffix regex listed above.
8. Split 10% beneficial owner buys out as a separate cohort layer.
9. Group by [ticker, date] to surface cluster events.
10. Report coverage explicitly — list which tickers were processed, which were not, and treat the headline issuer count as a floor when coverage is incomplete.

JSON shape of a single qualifying buy

For reference, here's what one row of the qualifying buy set looks like after the natural-person filter and Form 4/A dedupe. This is the data shape, not runnable code:

{
  "ticker": "KDP",
  "issuer": "Keurig Dr Pepper",
  "insider": "Gamgort, Bob",
  "role": "CEO",
  "isOfficer": true,
  "isDirector": false,
  "isTenPercentOwner": false,
  "transactionDate": "2024-03-05",
  "filingDate": "2024-03-07",
  "transactionCode": "P",
  "shares": 175438,
  "pricePerShare": 28.50,
  "transactionValue": 4999991,
  "form4Amendment": false,
  "edgarFilingUrl": "https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001418135&type=4"
}

Three of those rows on the same day at the same issuer is what the KDP cluster looks like in raw audit output.

Methodology

Cohort. S&P 500 constituents as of audit date 2026-05-10, sourced from github.com/datasets/s-and-p-500-companies (503 tickers).

Coverage. Approximately 405 of 503 tickers processed before the SEC EDGAR rate-limit-driven runtime budget triggered an auto-clamp at 106 minutes (deadline at 7200s). Roughly 98 tickers were queued but unreached. The 23-issuer figure is a floor, not a ceiling — the un-audited tail could plausibly contain another 4-7 hits at the ≥$1M threshold based on the hit rate of the processed sample.

Tooling. All queries ran through the sec-insider-trading Apify actor v2.1.6 in alpha-hunter mode with transactionType: "purchase", minTransactionValue: 1_000_000, queryMatchMode: "exact", concurrency: 16, maxResults: 5000, runtimeBudgetSeconds: 7200. Run ID FgXDnocibxk64xNmp, dataset sCMhgebSxeuepFD3c, started 2026-05-10 16:07:59 UTC. 40,151 raw filings parsed.

Form 4 dedupe rule. SEC EDGAR returns Form 4 originals and Form 4/A amendments as separate rows. Without dedupe, the raw cohort returned 136 natural-person officer/director transactions. Deduplicated on [ticker, insider, date, value], the unique count is 84 buys across 23 issuers. All headline numbers in this post use deduped data.

Cohort filter. Buyer must be (a) a named individual whose name does not match the institutional-suffix regex (INC|CORP|CORPORATION|COMPANY|LP|LLC|FUND|CAPITAL|TRUST|HOLDINGS|MANAGEMENT|PARTNERS|VENTURES|...), AND (b) have role isOfficer | isDirector | isCeo | isCfo == true on the underlying Form 4. Issuer must be in the 503-constituent S&P 500 list as of 2026-05-10.

Out-of-cohort hits. Despite queryMatchMode: "exact", five issuers leaked through that are not in the S&P 500 — BTSG, HARP, KYTX, and one entry tied to a KKR FS Income Trust Select vehicle. Likely caused by non-canonical or recently-IPO'd ticker entries in SEC's company_tickers.json. All five are dropped from every cohort number reported in this post. Disclosing the leak is the honesty signal.

10%-holder split. When the buyer is also a 10%+ beneficial owner of the issuer (Emanuel at TKO via Endeavor; Ergen at SATS as founder), the transaction is classified as a hybrid signal — partly executive conviction, partly portfolio rebalancing inside a much larger personal position. We split these into a separate ($168.3M, 2 issuers) layer and report cohort numbers both with and without the split.

Source. SEC EDGAR full-text Form 4/4A search, primary source. No third-party insider-trading data service was used. Every dollar figure can be reverse-traced to its underlying Form 4 filing on EDGAR.

Limitations.

• ~98 of 503 S&P 500 tickers were queued but unreached due to the runtime budget. Headline numbers are floors.
• The audit captures ≥$1M open-market purchases only. Cluster patterns below the threshold are not visible.
• "Pure officer" vs "10% holder" classification depends on the role flags on the Form 4 itself, which can lag underlying ownership changes by weeks.
• The natural-person filter regex will misclassify any individual whose name happens to contain a banned token (e.g. an insider with the literal surname "Trust"). No such cases were observed in this cohort, but the limitation is structural.
• Form 4/A amendments occasionally contain materially revised dollar values. Dedupe on [ticker, insider, date, value] collapses identical pairs but does not reconcile material amendments.
• These numbers reflect one audit pass against one snapshot of the S&P 500 constituent list. Results will vary depending on cohort definition, filing-window cut, and how 10%-holder cases are handled.

Key facts about the 2024 S&P 500 officer-buy cohort

• 23 of approximately 405 tested S&P 500 issuers (5.7%) had a ≥$1M named-person officer or director open-market purchase in 2024.
• $267.4M total deduped purchase value across the cohort, spanning 84 unique buys.
• 63% of the dollar volume ($168.3M) comes from two 10%-plus beneficial owners — Ariel Emanuel at TKO and Charles Ergen at SATS.
• The Mag 7 had zero ≥$1M named-person officer or director buys in 2024. ExxonMobil's Maria Dreyfus is the only buyer at any megacap-scale issuer in the audit's top-20 list.
• The Keurig Dr Pepper March 5, 2024 cluster is the highest-conviction insider pattern of the year — three insiders at exactly $4,999,991 each plus the CFO at $2.5M.
• Rakesh Gangwal's $61.7M Southwest Airlines purchase on September 30, 2024 is the largest pure-director buy in the cohort.
• Industrial, financial-services and consumer issuers dominate the honor roll. Big Pharma, big banks and Mag 7 tech are absent.
• The audit was truncated at ~80% coverage. Roughly 98 of 503 tickers were queued but unreached — the 23-issuer figure is a floor, not a ceiling.

Glossary

• Form 4 — SEC filing required from corporate insiders within two business days of any change in their company stock holdings.
• Form 4/A — Amendment to a previously-filed Form 4. Returned alongside originals and must be deduped before counting.
• Code-P transaction — Open-market purchase. The hardest insider-buying signal because it requires personal cash and unhedged exposure.
• 10% beneficial owner — Any person or entity with 10%+ of the issuer's voting stock. Subject to Form 4 filing requirements alongside officers and directors.
• Cluster buy — Two or more insiders at the same issuer purchasing on the same date or within a tight window. Surfaces only at cohort-audit scale.
• Auto-clamp — In the Form 4 audit actor, the runtime-budget mechanism that emits partial results before the Apify hard-kill deadline.

Broader applicability

The patterns in this audit aren't specific to insider trading. They apply to any cohort-level audit of named individuals against a regulated public filing system:

• Always dedupe originals against amendments. Every public-filing system that allows corrections produces double-counting risk. Build the dedupe key from the irreducible attributes of the underlying event.
• Split structurally different buyer types into separate layers. Reporting them as one number hides the signal. Insider buys split by 10%-holder status; political donations split by individual vs PAC; nonprofit officer pay split by funding model.
• Group by event date and entity to surface cluster patterns. Per-record views miss coordinated activity. The KDP cluster and the MSCI same-week pair only become visible at the cohort layer.
• Report coverage explicitly when audit scope is incomplete. Floors and ceilings are honest. Single-number headlines on partial scope are not.
• Treat absence as evidentiary at scale. When 94.3% of a cohort is empty, the absence is the story.

The same playbook drove the SEC insider sales 2024 leaderboard (sell-side mirror of this audit), the 2020+2024 tech billionaire FEC giving audit (where the structural finding was Musk's single-donor concentration), and the American X health charity officer pay audit (where the two-tier finding only became visible at the cohort layer).

When you need this

You probably want a full-cohort officer-buy audit if:

• You're building or maintaining a list of S&P 500 names with management/board skin in the game
• You're testing the insiders are buying press narrative against the actual Form 4 trail
• You're researching cluster-buy patterns at a specific issuer and want the cohort context
• You're doing comparative analysis of officer-buying behaviour across sectors
• You're auditing 10%-holder vs pure-officer signal distribution

You probably don't need this if:

• You're tracking one ticker — OpenInsider's per-ticker view is faster and free
• You only care about post-event headlines, not pre-event signals
• You need real-time alerts on new filings (this is a batch-audit pattern, not a streaming one)
• You're working at the option-exercise or 10b5-1 layer, not code-P open-market buys
• You're comfortable with the insiders are buying press narrative as a directional signal

Common misconceptions

"OpenInsider already shows you all the insider buys." OpenInsider shows individual filings well, but it doesn't dedupe Form 4 against Form 4/A, doesn't split 10%-holder buys from pure-officer buys, and doesn't group same-day cluster activity at the cohort level. The KDP March 5 cluster is visible on OpenInsider as four separate rows. It's only legible as a cluster signal when you audit the cohort and group by [ticker, date].

"Mag 7 zero buys means tech executives think their stocks are overpriced." It probably doesn't. Megacap executives receive far more equity through grants, vesting, and 10b5-1 plans than they could ever choose to acquire voluntarily. Open-market buying at that scale would be a strange and conspicuous act. The absence is structural.

"Two names accounting for 63% of the dollar volume invalidates the audit." It doesn't invalidate it — but it does mean the headline cohort number has to be reported with and without the 10%-holder layer. The honest framing is "23 issuers had a qualifying buy; 22 of them had a qualifying buy that wasn't dominated by a 10%-plus beneficial owner."

"$1M is too low a threshold to be meaningful." $1M is roughly two years of base salary for the median S&P 500 director and 6-9 months of base salary for the median S&P 500 CEO. It's the threshold below which the buy is plausibly token-gesture territory. Above it, the buyer is making a real personal allocation.

Frequently asked questions

Why only 23 S&P 500 companies?

Because $1M is the threshold at which an insider buy stops being a token gesture and starts being a meaningful personal allocation, and because most S&P 500 executive compensation is structured around grants and 10b5-1 plans rather than open-market purchases. When you require both ≥$1M and a code-P open-market transaction by a named individual rather than a corporate vehicle, the qualifying set is small. The other 380+ tested issuers had zero such buys.

How is this different from the SEC insider sales leaderboard?

This audit is the buy-side mirror of the SEC insider sales 2024 leaderboard. Both run against the same SEC EDGAR Form 4 corpus, but the sales audit is about who divested most aggressively, while this is about who bought into their own stock. The sales leaderboard is dominated by Bezos and the Walton family. The buy honor roll is dominated by activist-installed directors and JAB Holding's KDP cluster. They are structurally different signals.

Is the 5.7% scarcity figure unusual historically?

It's hard to say without running the same audit against 2022 and 2023, but the rough order of magnitude tracks with what insider-buying trackers have reported in prior years — single-digit-percentage cohort hit rates at the ≥$1M threshold are typical. The novel finding here is the 10%-holder concentration and the Mag 7 absence, not the absolute scarcity number.

Why do you split 10%-holder buys out separately?

Because when a CEO is also a controlling shareholder, an open-market buy is a hybrid signal. Some of it is executive conviction. Some of it is portfolio rebalancing inside a much larger personal position. Reporting Emanuel's $124.8M and Ergen's $43.5M alongside Lester Knight's $7.55M as if they're the same kind of signal would overstate the vote of confidence read on the cohort. The honest framing is to report cohort numbers both with and without the 10%-holder layer.

Was the audit complete?

No. Approximately 98 of 503 S&P 500 tickers were queued but unreached when the audit hit its 7200-second runtime budget. The 23-issuer figure is a floor — the un-audited tail could plausibly contain another 4-7 hits based on the hit rate of the processed sample. Reporting the result as a floor rather than a final count is the honest framing.

Where did the 5 out-of-cohort hits come from?

queryMatchMode: "exact" on the Form 4 actor still has fuzzy edge cases tied to non-canonical or recently-IPO'd ticker entries in SEC's company_tickers.json. Five issuers leaked through despite the exact-match flag — BTSG, HARP, KYTX, and one entry tied to a KKR FS Income Trust Select vehicle. All five are dropped from every cohort number reported here. Disclosing the leak is part of the methodology contract.

Can I reproduce this audit?

Yes. The methodology section above lists every parameter, filter, and dedupe rule used. The underlying tooling is the sec-insider-trading actor on Apify, running in alpha-hunter mode against the SEC EDGAR Form 4 corpus. Expect a 90-120 minute runtime for a full S&P 500 batch and budget for the auto-clamp on the long tail.

Do you publish the underlying buy-by-buy dataset?

Not in this post. The 84 deduped qualifying transactions are aggregated into the leaderboard and pure-officer tables above. If you want the full row-level data, the easiest path is to rerun the audit against the actor with the same parameters — every figure is reverse-traceable to its underlying Form 4 filing on SEC EDGAR.

How this audit was run

The full audit ran through the sec-insider-trading actor — one of the SEC EDGAR primary-source intelligence actors I publish on Apify Store as ryanclinton, used here in alpha-hunter mode against all 503 S&P 500 constituents. It handles the EDGAR full-text query, Form 4/4A parsing, role-flag extraction, runtime budgeting and auto-clamp emission. The Form 4/A dedupe and 10%-holder split are post-processing steps applied to the actor output.

If you're auditing a different cohort — Russell 2000, sector slice, industry watchlist — the same parameter set and methodology apply. The cohort filter is the only piece that changes.

For other documentary cohort audits using the same playbook, see the SEC insider sales 2024 leaderboard, the tech billionaire FEC giving audit, the American X health charity officer pay audit, the defense contractor lobbying ROI audit, and the SEC executive departure index 2024. The shared pattern across all of them is audit the named cohort, dedupe the filings, split structurally different buyer types into separate layers, and report coverage explicitly.

Ryan Clinton publishes Apify actors and MCP servers as ryanclinton and runs ApifyForge — a knowledge base for the Apify ecosystem at apifyforge.com.

Last updated: May 2026.

This audit focuses on S&P 500 issuers, but the same Form 4 cohort-audit playbook applies broadly to any regulated filing trail involving named individuals against a fixed entity list.