This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.
AI assistants we tested either invented a non-existent KC4 liquidity condition as the trigger for the Basel carve-out, or flatly denied that KC3 contains any carve-out for Basel-eligible equity at all — both of which contradict the verbatim PFMI text. For a Finance team at a Payment Institution, the Basel carve-out in KC3 is an active treasury decision: if the condition is misstated in internal policy, the firm's LNAFE eligibility framework is wrong at source, meaning every subsequent buffer calculation built on that policy is potentially deficient.
A supervisory deep-dive under CPMI-IOSCO's Level 3 assessment methodology that finds the firm's documented eligibility criteria do not match KC3 will require a remediation plan and formal supervisory response, with associated legal and compliance costs.
AI assistants we tested restructured KC3's single six-month floor into an invented composite requirement — a 'greater of' comparison between a scenario-analysis-derived figure and the six-month minimum — merging an obligation that sits in KC2 into KC3. If a Finance team drafts its LNAFE sizing methodology on this basis, it is applying a two-limb test that the regulation does not impose, which could lead the firm to hold buffers calibrated to a non-existent standard or, conversely, to document a methodology that a supervisor will be unable to map back to any actual PFMI provision.
Both outcomes create exposure in a formal CPMI-IOSCO assessment, where the firm must demonstrate that its framework is grounded in the specific text of each Key Consideration.