This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.
A Compliance team that asks AI tools about the Basel equity carve-out in PFMI Principle 15 KC3 may receive either a fabricated KC4 liquidity test grafted onto KC3's qualifying condition, or a flat denial that the carve-out exists at all — both positions contradict the KC3 verbatim text. Either version, embedded in a PFMI-readiness policy or a capital adequacy framework, misstates the condition under which Basel-standard equity counts toward an FMI's LNAFE requirement.
A Payment Institution that applies the fabricated KC4 liquidity test may over-restrict eligible equity; one that accepts the denial of any carve-out has a policy that diverges from the published standard on its face. When a primary supervisor reviews the GBR capital framework and identifies the mischaracterisation, the firm faces a formal deficiency finding and directed remediation — alongside the reputational signal that the policy was not verified against primary sources.
AI tools tested on KC3's LNAFE minimum produced a fabricated 'greater of' dual-track test — inserting a scenario-analysis sizing leg from KC2 into KC3's simple six-month floor. A Compliance team that embeds this framing in an internal capital standard has simultaneously imposed a stricter KC3 floor than the standard requires (the scenario-analysis calculation can exceed six months of operating expenses, inflating GBR capital unnecessarily) and misrepresented the KC architecture to any regulator reviewing the submission.
The structural mischaracterisation — presenting two distinct Key Considerations as a single dual-limb test — is the kind of foundational error that signals to supervisors that the team has not engaged with the PFMI primary text. Remediation requires rewriting the framework and explaining the source of the error to Internal Audit and the primary supervisor.
AI tools tasked with summarising the November 2025 CPMI-IOSCO Level 3 assessment process produced a timeline ending in 2024, dropping the further engagement rounds and findings-sharing phase that ran through April 2025. A Compliance team at a trade repository or payment institution that incorporates this summary into a regulatory engagement methodology note has produced a document that misrepresents how CPMI-IOSCO validated findings with FMIs — specifically, it omits the final year of the assessment lifecycle, understates the recency of the conclusions, and mischaracterises the process CPMI-IOSCO used before publication.
In a direct regulator meeting, a supervisor who is familiar with the assessment — or who pulls the BIS publication — would identify the error immediately, creating a credibility problem that no subsequent clarification fully resolves.