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Retail Banking × Compliance — Singapore · published 2026-05-28 · methodology v2.1

AI Hallucinations Affecting Compliance at Retail Banking Firms in Singapore

Findings — impact summary

This is the consolidated view of findings. Click 'see details →' on any item for the full details for each finding.

  1. Finding 1. Fabricated notice designation for financial holding companies

    A Compliance team preparing guidance on the regulatory perimeter — for example, advising treasury or risk on which group entities are subject to MAS capital requirements — could incorporate 'Notice FHC-N637' as a genuine regulatory reference. That fabricated label would then appear in internal policies, board papers, or communications with MAS. When MAS or an external auditor tests the firm's regulatory mapping, the citation to a non-existent notice would expose a material gap in the firm's regulatory understanding, potentially triggering a supervisory request for remediation of all downstream policies built on that reference. The cost is not limited to correction of the label — it includes a full review of any entity-scope analysis that relied on the AI's answer.

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  2. Finding 2. Mischaracterisation of yellow highlighting in MAS Notice 637 amendment PDFs

    A Compliance team reviewing MAS Notice 637 (Amendment) 2024 — for example, to update the firm's capital adequacy implementation timeline or identify which provisions have a deferred effective date — would use the yellow-highlighting convention to prioritise their reading. If the team accepts the AI's explanation (that highlights mark general visual aids, defined terms, or editorial annotations), they will misidentify which provisions are subject to a different operative date. This could result in the firm implementing a provision either too early or too late, creating a period of non-compliance. For provisions touching Tier 1 capital composition or RWA calculation methodologies, a timing error in implementation carries direct regulatory capital consequences and potential MAS supervisory scrutiny.

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  3. Finding 3. Incorrect framework attribution for Annex 4D scope and exclusions

    A Compliance or risk team consulting Annex 4D in the course of calculating risk-weighted assets or leverage ratio exposures would apply the wrong methodology if the AI's framework attribution is incorrect. Misassigning off-balance sheet items to the leverage ratio framework instead of the Standardised Approach credit risk framework — or vice versa — would produce incorrect capital calculations across the affected portfolio. Given that capital ratio calculations feed directly into the firm's regulatory capital reporting to MAS, an error of this kind carries both a misreporting risk and the potential for capital buffers to be understated, with consequences for MAS's assessment of the firm's capital adequacy.

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  4. Finding 4. Unverified content attribution for Annex 6C

    If a Compliance or risk officer uses the AI's characterisation of Annex 6C to draft or review the firm's prudent valuation framework — including the firm's methodology for calculating additional valuation adjustments on fair-valued instruments — and the annex's actual content differs from the AI's description, the firm's internal valuation policy may not correspond to MAS's requirements. This matters because prudent valuation deficiencies are a recurring focus of MAS supervisory reviews of trading book practices. A policy that cannot be traced accurately to the relevant MAS Notice 637 annex is vulnerable to a finding in the next supervisory examination, with potential requirements for remediation and re-submission of affected valuations.

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  5. Finding 5. Unverified characterisation of Division 4 of Part VI

    A Compliance team advising on capital instrument eligibility — for example, reviewing whether a proposed Tier 2 instrument meets MAS requirements, or preparing documentation for a capital instrument issuance — would look to Part VI and its divisions to confirm the applicable requirements. If Division 4 does not in fact cover capital instrument submission requirements as the AI suggested, any internal guidance or board paper built on that characterisation would misstate the regulatory basis. For capital instrument transactions, which require MAS engagement and may involve public disclosure, a misstatement of the applicable regulatory framework creates both a supervisory risk and a reputational risk if the error becomes apparent to counterparties or investors.

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