AI Hallucination ResearchAudiencesPractitionersInternational / MultilateralPublic Auditors › Implementation Monitoring of the PFMI: Level 3 Assessment on General Business Risks
Practitioners — Public Auditors · updated 2026-06-03 · methodology v2.3
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AI on Implementation Monitoring of the PFMI: Level 3 Assessment on General Business Risks for Public Auditors 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. KC3 Basel carve-out condition fabricated with KC4 liquidity test
    RLB-F-INT-BIS-CPMI-IOSCO-PFMI-L3-GENERAL-BUSINESS-RISK-2025-Q002

    An auditor relying on this AI response would advise that Basel/CRD equity can only count toward the KC3 LNAFE buffer if the underlying assets also satisfy a KC4 liquidity test — a condition that appears nowhere in KC3. A CCP applying this fabricated eligibility screen would potentially exclude compliant equity capital from its LNAFE calculation, understating its buffer and generating a false compliance gap. The client loses a correct eligibility analysis; the auditor's sign-off references a standard that does not exist, exposing the opinion to immediate challenge against the PFMI source text.

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  2. Six-month LNAFE floor inflated into invented dual-track minimum
    RLB-F-INT-BIS-CPMI-IOSCO-PFMI-L3-GENERAL-BUSINESS-RISK-2025-Q003

    An auditor accepting the 'greater of' framing would assess a CCP's LNAFE buffer against a dual-track minimum — the six-month floor and a scenario-analysis sizing leg — when KC3 contains only the six-month floor. The scenario-analysis obligation sits in KC2 and is a separate, prior step in the compliance analysis. The practical effect is that an auditor applying the fabricated composite standard could reach a different compliance conclusion than one reading KC3 directly, and would produce a gap analysis built on a structural misreading of the KC architecture.

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