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 tools we tested identified that a January 2026 correction notice restored a previously inadvertently removed appendix, but omitted the specific identity — Appendix A to Subpart H, titled 'Guidance on the Application of §§23.434 and 23.440 for Swap Dealers That Make Recommendations to Counterparties or Special Entities,' which has been in effect since 2012. For a Compliance team updating written supervisory procedures or training materials on special entity obligations, citing the correction without pinning the appendix identity leaves the guidance authority unverified.
In a CFTC examination of business conduct controls, an inability to accurately trace the guidance applicable to §§23.434 and 23.440 recommendations — including which version of the appendix was operative at each point — is a credible documentation gap.
AI tools we tested described CFTC Staff Letter 25-49 as covering ITBC swaps on U.S. SEFs and DCMs — directly contradicting the letter's actual scope, which is limited to Eligible UK Trading Venues authorised by the FCA. When challenged, the AI retracted its answer and acknowledged the error.
For a Compliance team advising a rates or credit desk on whether execution through a UK MTF or OTF qualifies for the letter's relief, an AI answer that maps the relief onto U.S. venues is operationally backwards: it fails to extend relief the firm actually qualifies for, while simultaneously suggesting relief applies to venues outside the letter's scope. The CFTC's examination posture on cross-border swap execution compliance is well-established; a Compliance memo based on the AI's initial characterisation would be incorrect on its face.
AI tools we tested interpreted 'eliminated in its entirety' to mean PTMMM disclosure no longer applies to any swap type under §23.431 — including cleared CDS. In fact, the December 2025 final rule deleted the §23.431(a)(3) container provision and moved price and compensation disclosure obligations into adjacent paragraphs; cleared swaps were already outside PTMMM's scope before the amendment. A Compliance team drafting updated disclosure procedures for a multi-product swap desk that runs both uncleared and cleared products needs to preserve disclosure obligations for the uncleared book precisely.
An AI-generated overclaim of the PTMMM elimination embedded in Compliance policy documentation creates a control gap that regulators and internal audit can both identify — and that trading desk reliance on that documentation would then propagate into live execution.