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Disclosure letter

A disclosure letter sets out the seller's exceptions to the warranties in a purchase agreement. Anything fairly disclosed in it generally cannot support a warranty claim later.

Also called disclosure schedule

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Definition

A disclosure letter is a document the seller gives the buyer before the purchase agreement is signed, listing exceptions to the warranties in that agreement. If a matter is fairly disclosed, you generally cannot later bring a warranty claim about it, because you knew about it when you signed. The term is most used in the UK. In US deals, disclosure schedules attached to the agreement do a similar job.

Warranties and indemnities

Warranties are the seller's statements of fact about a business in the purchase agreement; indemnities are promises to reimburse specific losses. Together they decide who bears risks that diligence could not rule out.

Worked example

Oakhollow Joinery Ltd is a fictional UK company. The share purchase agreement includes a warranty that the company is not involved in any dispute.

The disclosure letter states that a former customer has threatened a £50,000 claim over a faulty staircase. Because that claim has been disclosed, the buyer could not rely on the warranty if the customer sued. Instead, the buyer negotiates a specific indemnity from the seller covering that claim, with £50,000 held back from the price until it is resolved.

Why buyers care

A warranty is only as strong as what has been disclosed against it. Read the disclosure letter early and carefully with your lawyer, not in the final hours before signing.

Push back on general disclosures that try to treat everything in the data room, or every public register, as disclosed. Ask for each disclosure to be specific enough that you can understand the problem and its likely cost. When something new appears late, treat it as new information: it may justify a price change, a specific indemnity or more time to investigate.

Data room

A data room is a secure online folder where a seller shares documents for due diligence, with access controlled and usually logged.

  • Warranties and indemnities

    Warranties are the seller's statements of fact about a business in the purchase agreement; indemnities are promises to reimburse specific losses. Together they decide who bears risks that diligence could not rule out.

  • Data room

    A data room is a secure online folder where a seller shares documents for due diligence, with access controlled and usually logged.

  • Due diligence

    Due diligence is the investigation a buyer carries out before committing to a purchase, testing the finances, contracts, legal position and operations against what the seller has described.

  • Escrow

    Escrow is an arrangement in which an independent third party holds money until agreed conditions are met. In a business sale it keeps part of the price available to cover claims after completion.

  • Asset sale versus share sale

    In an asset sale you buy selected assets of a business; in a share sale (a stock sale in the US) you buy the company itself, with its full history. The choice shapes risk, tax and what needs consent.

  • Due diligence: what to check and in what order

    A sequence for due diligence that tests what could end the deal first, while it is still cheap to find out, and leaves the detailed and expensive work until the deal looks sound.

    10 minutes to read
  • From first call to letter of intent

    The steps between spotting a listing and signing a letter of intent, what to learn at each one and what a sound letter of intent should cover.

    10 minutes to read
  • Pending or threatened litigation

    A live or threatened claim can cost a business far more than any damages, and some claims follow the business to a new owner. Find every dispute, understand who carries it after the sale and price or protect against it.

    Severity: price it inLegal and compliance
  • Unpaid taxes a buyer could inherit

    Tax the business should have paid does not disappear when it changes hands. In a share sale it stays with the company you buy, and some unpaid taxes can follow even an asset purchase.

    Severity: price it inLegal and compliance
  • Figures that change between the teaser and later documents

    Revenue, profit or add-backs in the teaser or listing do not match the information memorandum, the management accounts or the tax returns. Some changes have a simple explanation; others mean the first figures were never real.

    Severity: price it inSeller and process

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