This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.
An accountant advising an FCM on investment policy adequacy who accepts the AI's uniform 10% concentration limit will produce an opinion that misses the 50% ceiling available for large-fund/large-manager combinations — potentially advising unnecessary diversification that increases transaction costs, or conversely failing to flag a concentration that the correct two-tier structure would have capped at 25% under the issuer-based limit. Either error ends up in a written deliverable. If the policy is subsequently reviewed by the CFTC on examination, the accountant's opinion will reflect a rule that does not exist in the final text.
An accountant reviewing an FCM's portfolio maturity analysis who does not independently verify the exclusion clause will apply the 24-month dollar-weighted average maturity limit to the full portfolio — including instruments the rule explicitly excludes. The practical effect is a stricter-than-required constraint on the portfolio, or a failure to catch a client's calculation error if the client has correctly applied the exclusion but the accountant has not. In either case the sign-off on the analysis is based on an incomplete reading of the rule, which becomes a liability issue if the engagement is later scrutinised.
An accountant coordinating a client's compliance calendar or reviewing SIDR update adequacy who accepts the AI's six-to-twelve month estimate for the SIDR compliance deadline will advise a window that does not exist — the actual deadline was March 31, 2025, approximately 38 days after the February 21, 2025 general effective date. A client that missed that deadline based on a compliance calendar built on incorrect AI output is exposed to a CFTC enforcement finding, and the accountant's advice record will show the wrong date was communicated.