The Double Insiders

• Key findings
• 250 member-ticker relationships since January 2025 where a member of Congress and a corporate insider bought the same company within 30 days — 115 companies, 40 members, 192 insiders.
• Nobody leads. Insider first: 123. Member of Congress first: 114. Same day: 13. The median gap is 13 days, in either direction.
• 35 relationships land within three days, and 13 on the same day. Those are the ones worth reading individually.
• UnitedHealth, May 16, 2025: new CEO Stephen Hemsley bought 86,700 shares at $288.57 ($25.02M); CFO John Rex bought $5.00M the same day; three directors added $1.6M that week. Michael McCaul's accounts bought UNH the same day, and again on the 20th.
• Eight members of Congress bought UnitedHealth during its 2025 collapse — the widest overlap of any company in the dataset.

1. Two insiders, two agencies, one stock

On May 16, 2025, Stephen Hemsley — three days into his second run as chief executive of UnitedHealth — bought 86,700 shares of his own company at $288.57. Twenty-five million dollars of his own money, into a stock that had just fallen off a cliff. His chief financial officer bought $5.00 million the same day. Three directors added $1.6 million across that week.

That is a Form 4 event: the SEC requires an officer or director to disclose a trade in their own company within two business days. It is also the loudest legal signal a management team can send. Nothing about it is subtle, and nothing about it is improper.

On the same day, the accounts of Michael McCaul, the Texas Republican, bought UnitedHealth. On the 20th, they bought more.

Those two facts live in different filing systems, under different laws, on different clocks, keyed by different identifiers. Nobody puts them on the same page. So we went looking for how often it happens.

2. Data and methodology

We took every stock purchase a member of Congress disclosed under the STOCK Act since January 1, 2025, and every open-market purchase filed on a Form 4 by a corporate insider in the same window, and matched them on ticker where the two trades fell within 30 days of each other. Only genuine purchases count on both sides: on the corporate side that means open-market buys of $10,000 or more, excluding option exercises, awards, tax-withholding dispositions and gifts, which are compensation events rather than decisions to buy.

Four corrections matter, because the naive version of this query is wrong by roughly a factor of three.

• Corrections applied
• Two filing conventions. Our Form 4 records carry both SEC transaction codes and free-text labels, written by two different parsers. Filtering on the code P alone silently drops 501 open-market purchases logged as purchase. Both are counted.
• One corrupt row. A single filing carries an implausible per-share price, and on its own it inflates the average purchase to $304 billion. Rows with a per-share price outside a sane range are excluded. The clean total of all Form 4 open-market buying in the window is roughly $13.4 billion.
• Tranche inflation. One insider decision can be filed across many rows — Elon Musk's September 2025 Tesla purchase is 25 Form 4 rows for a single event. Tranches are collapsed to one event per insider, per ticker, per day.
• Duplicate disclosures. The congressional record contains each disclosure twice under case-variant transaction types. It is deduplicated before matching.

Counting distinct member-ticker relationships rather than raw row pairs gives 250. The uncorrected pair count is 753, and it is not used here. Where a member and a ticker overlap more than once, the relationship is measured at its tightest gap.

3. The result: nobody is front-running anybody

The reason to build this dataset is the suspicion behind it: that members of Congress, sitting on committee calendars and briefings, get there before the people who actually run the companies. The data says no.

250 relationships, measured at the tightest overlap in each. Grey segment is same-day.

123 to 114, with 13 ties. Nine relationships separate the two sides out of 250. The median gap is 13 days, and it is 13 days whichever way it runs. There is no edge here, in either direction, and whatever else is true about congressional trading, this particular accusation does not survive contact with the record.

What the distribution does contain is a tail. 35 of the 250 relationships land within three days and 13 are same-day — far tighter than a 13-day median would produce on its own. Those are worth reading one at a time.

Relationships counted once per member per ticker at the tightest overlap; insider tranches collapsed to one event per insider, per ticker, per day. Companies with fewer than four overlapping members are omitted. Verified July 15, 2026.

4. UnitedHealth: the tightest case in the set

May 2025 was the worst month in UnitedHealth's history. The chief executive resigned abruptly on the 13th. The company withdrew its full-year outlook. The Justice Department was running a criminal probe into its Medicare billing practices. The stock fell from $308.01 to $274.35 between two closing bells — eleven percent in a single day.

Stephen Hemsley, who had run the company for a decade before, took the job back on the 13th. Three days later he bought $25.02 million of the stock. The market read it exactly as intended: this is management saying it is not over.

SEC Form 4 filings. Every figure in this table matches contemporaneous trade-press reporting of the same filings to the share and the cent — an independent check that our parse reproduces the record rather than approximating it. Verified July 15, 2026.

McCaul's accounts bought UnitedHealth on May 16 in the $15,001–$50,000 bracket, with the stock at $291.91, and again on May 20 in the $50,001–$100,000 bracket at $321.58.

Here is the part that usually gets left out of a story shaped like this one. A Form 4 has two business days to reach the SEC. On May 16, Hemsley's purchase was not public. McCaul could not have been copying it, because there was nothing yet to copy. The record does not merely fail to support a copying theory — it rules it out.

So the two purchases are independent. A chief executive and a congressman looked at the same collapsing company in the same week and reached the same conclusion. Only one of them had a fiduciary duty to explain why.

Eight members of Congress bought UnitedHealth during 2025, more than any other company in this dataset. The stock closed at $291.91 on the day Hemsley and McCaul bought. It has since recovered well above that.

5. Discussion: the same table, not the same seat

The popular theory of congressional trading is a theory about information: members see things first, and trade on what they see. This dataset tests a specific version of that theory against the sharpest possible benchmark — the people who run the companies — and the version fails. Congress does not get there first. It gets there at the same time, roughly half the time, on a thirteen-day median in both directions.

That is not an exoneration of anything, and it is not what this paper is for. Committee-timing patterns, jurisdiction overlap and disclosure delay are all real and documented elsewhere in this series. What this paper removes is one specific, popular, and apparently false claim: that Congress is systematically ahead of corporate insiders.

What it leaves is a picture that is stranger and harder to legislate. The people writing healthcare law and the people running the healthcare company were reading the same news, in the same week, and putting their own money into the same stock. Not because one had a secret. Because they were sitting at the same table.

6. Limitations and caveats

The window is a choice. Thirty days is wide enough to catch a shared thesis and narrow enough to exclude coincidence. A tighter window would produce fewer relationships and a sharper tail; a wider one would drown the signal in the fact that popular stocks are bought constantly by everyone. The 123–114 split is stable in the sense that it is near-even, not in the sense that it is a precise measurement.

Congressional trade dates are dates, not times. A STOCK Act filing records the day, never the hour. For the 13 same-day relationships, the record cannot say which came first within the day — only that both happened.

Members do not necessarily place their own trades. McCaul's accounts are professionally managed and file at a volume — more than 16,000 trades — that no individual executes personally. A trade appearing under a member's name is a disclosure obligation, not evidence of a personal decision.

The Form 4 body parse is a subset. Our corporate-insider table holds parsed transactions, not the full SEC filing index. Coverage is broad but not a census, and a missing insider would produce a missing relationship rather than a false one. The count is a floor.

Nothing here alleges wrongdoing. Insiders may buy their own stock in open windows and must disclose it. Members of Congress may buy stock and must disclose it. Every trade in this paper was filed as the law requires, and the single tightest case in the entire dataset is one the record actively exonerates.

7. Conclusion

Two disclosure regimes, built forty years apart for different reasons, quietly describe the same market. Read separately, each is a compliance artifact. Read together, they answer a question people argue about constantly and almost never test: does Congress beat the insiders?

One hundred and twenty-three to one hundred and fourteen. It does not.

The interesting finding was never going to be the winner. It is that the contest exists at all — that on 115 companies since January 2025, the same trade occurred to a chief executive and to a legislator within the same month, and that both of them were required to tell us, in systems neither designed to be read next to the other.

Frequently asked

References & data sources

1. SEC Form 4 — corporate insider transactions; open-market purchases of $10,000 or more, excluding option exercises, awards, tax-withholding dispositions and gifts.
2. STOCK Act Periodic Transaction Reports — congressional stock purchases disclosed since January 1, 2025, deduplicated before matching.
3. UnitedHealth, May 2025 — the CEO transition, the withdrawn outlook and the Justice Department probe are public record; the Form 4 figures in Table 2 match contemporaneous trade-press reporting of those filings.
4. Image credit — UnitedHealthcare Corporate Headquarters, December 8 2024 — Chad Davis, CC BY 2.0 via Wikimedia Commons.

Keep pulling the thread

Not financial advice. All data from public federal disclosures.