AI Labs · updated 2026-06-03 · methodology v2.1

Finding on 'Q004 Probe' for Claude Opus 4.7 with web search ON

RLB Citation ID: RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47

What the RLB Specialist Panel found

Finding on 'Q004 Probe' for Claude Opus 4.7 with web search ON

Question (paraphrased to protect IP): Which categories of swap instruments were actually subject to the pre-trade mid-market mark disclosure requirement under §23.431(a)(3) prior to its elimination by the December 2025 CFTC final rule, and does 'eliminated in its entirety' mean the requirement was removed for all swap types?
AI's response: "PTMMM disclosure is no longer required for any swap subject to § 23.431, including:...Cleared credit default swaps (index and single-name)...The exemption is product-agnostic across the desk's covered swap book."
Regulator's text: The Commission is eliminating the PTMMM Requirement in its entirety by deleting paragraphs (i) and (ii) of §23.431(a)(3) and moving the price disclosure requirement currently in such paragraph (i) and the compensation disclosure requirement currently in such paragraph (ii) into paragraphs (2) and (3) of §23.431(a), respectively.
Why the AI went wrong: The model extended "eliminated in its entirety" to mean the underlying disclosure obligations were removed, when the rule's actual operation was a paragraph-level restructuring — the price and compensation disclosure requirements were moved to different subsections of §23.431(a), not abolished. The model produced a product-agnostic exemption claim unsupported by the rule text, implying that a swap dealer's PTMMM obligations across its entire covered book were extinguished. That is a material mischaracterisation of what the amendment did.
Cited source(s):

Impact for this audience

This failure is a post-training calibration gap: the model interpreted 'eliminated in its entirety' as obligation extinguishment when the rule's operation was a paragraph-level reorganisation — the disclosure and compensation requirements moved subsections rather than disappearing. The model generated a product-agnostic exemption claim unsupported by the rule text, suggesting the calibration signal for 'eliminate/delete' in a rulemaking context does not adequately distinguish structural reorganisation from substantive removal. No cited sources were produced, indicating this was a training-reconstruction failure rather than a retrieval failure.

References — raw findings (per AI model)

RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47 Claude Opus 4.7 (web search on)

This finding also affects

← Previous finding Finding on 'Q003 Probe' for Claude Opus 4.7 with web search ON Next finding → Finding on 'Q002 Probe' for Claude Sonnet 4.6 with web search ON

Cite this finding

Each finding has a stable Citation ID (RLB-F-… for aggregated case-study findings, RLB-H-… for raw per-model hallucinations) — like a DOI, the ID always resolves to the canonical finding even if URLs change.

RLB Citation ID: RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47

Plain text Download

RegLeg Specialist Panel (2026). "Finding on 'Q004 Probe' for Claude Opus 4.7 with web search ON — AI Labs." Citation ID: RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47. RegLegBrief AI Hallucination Research, published 2026-06-03. https://reglegbrief.com/regulators/j3/us/cftc/swap-dealer-business-conduct-documentation-2025/whitepaper/finding/US-CFTC-US-001-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-v1-004--opus-47-websearch/

APA 7th edition Download

RegLeg Specialist Panel. (2026). Finding on 'Q004 Probe' for Claude Opus 4.7 with web search ON [Hallucination finding RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/us/cftc/swap-dealer-business-conduct-documentation-2025/whitepaper/finding/US-CFTC-US-001-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-v1-004--opus-47-websearch/

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, Finding on 'Q004 Probe' for Claude Opus 4.7 with web search ON [RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47], RegLegBrief AI Hallucination Research (June 03, 2026), https://reglegbrief.com/regulators/j3/us/cftc/swap-dealer-business-conduct-documentation-2025/whitepaper/finding/US-CFTC-US-001-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-v1-004--opus-47-websearch/.

BibTeX Download

@misc{reglegbrief_RLB_H_US_CFTC_SWAP_DEALER_BUSINESS_CONDUCT_DOCUMENTATION_2025_Q004_Opus47,
  author    = {RegLeg Specialist Panel},
  title     = {Finding on 'Q004 Probe' for Claude Opus 4.7 with web search ON},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-H-US-CFTC-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-Q004-Opus47},
  url       = {https://reglegbrief.com/regulators/j3/us/cftc/swap-dealer-business-conduct-documentation-2025/whitepaper/finding/US-CFTC-US-001-SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-v1-004--opus-47-websearch/}
}

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