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Investment Banking × Governance & Company Secretarial — International / Multilateral · updated 2026-05-30 · methodology v2.3
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AI on Principles for Financial Market Infrastructures (PFMI) for Governance & Company Secretarial teams at Investment Banking firms in international jurisdictions

This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.

  1. PFMI Principle 2 board risk committee — mandatory vs conditional
    RLB-F-INT-BIS-CPMI-IOSCO-PFMI-2012-Q022

    When a Governance or Company Secretarial team at an investment banking firm asked AI tools whether the PFMI requires FMI boards to establish a dedicated risk committee, the AI cited a specific key-consideration sub-number and quoted regulatory language stating the requirement is conditional — content that does not correspond to the published regulation. A board paper or governance framework built on this answer would misrepresent the firm's understanding of what the PFMI mandates, potentially leading to a governance structure that falls short of regulatory expectations.

    If the firm operates as a participant in or indirect overseer of a PFMI-regulated infrastructure, and if regulators or counterparties scrutinise the firm's governance representations, the error could require a formal correction to board minutes and policy documentation. The remediation cost — legal review, board re-presentation, and potential regulatory disclosure — is disproportionate to the effort that independent verification of the source text would have required.

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