---
type: "AILabsWhitepaper"
title: "Hallucination findings: CPMI-IOSCO Consultation on Updated Guidance and Public Disclosures to Implement Initial Margin Proposals"
slug: "CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026-general-v1"
audience: "general"
regulation_slug: "CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026"
regulation_id: "320328"
body_id: "BIS-CPMI-INT-001"
jurisdiction_code: "INT"
j_level: "J1"
regulator_short_code: "BIS-CPMI"
methodology_version: "2.0"
substrate_version: 1
generated_at: "2026-06-07T07:58:36.486862+00:00"
published_at: "2026-06-07T07:58:36.486862+00:00"
license: "CC-BY-4.0"
resource: "https://reglegbrief.com/regulators/j1/int/bis-cpmi/CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026/ai-labs/"
timestamp: "2026-06-16T00:00:00+00:00"
---

# Hallucination findings: CPMI-IOSCO Consultation on Updated Guidance and Public Disclosures to Implement Initial Margin Proposals

- **Regulation.** [`CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026`](/okf/regulations/CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026.md) — CPMI-IOSCO Consultation on Updated Guidance and Public Disclosures to Implement Initial Margin Proposals
- **Regulator.** [`BIS-CPMI-INT-001`](/okf/bodies/BIS-CPMI-INT-001.md)
- **Audience.** general
- **Methodology.** 2.0
- **Generated.** 2026-06-07T07:58:36.486862+00:00

## Full whitepaper

# Hallucination findings, CPMI-IOSCO Consultation on Updated Guidance and Public Disclosures to Implement Initial Margin Proposals

_Jurisdiction: INT ; Body: BIS-CPMI-INT-001 ; Regulation: CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026_

This page lists each instance in which a tested AI assistant produced an answer that the regulator's own published text contradicts. Each row links the assistant's claim, the contradicting regulator text, and the status of any source the assistant cited.

**Citation status legend**:
- _Fabricated_, the URL the assistant cited does not exist as a public document.
- _Inaccessible_, the URL exists but its content is not available for public verification.
- _Accessible-but-contradicts-claim_, the URL is reachable and its content does not support the assistant's claim.

**Question text below is paraphrased to protect IP** in the underlying question bank.

---

| # | Subject | Question (paraphrased) | Assistant claim | Regulator says | Cited source(s) |
|---|---|---|---|---|---|
| 1 | opus-47-websearch | How many policy proposals does the January 2025 BCBS-CPMI-IOSCO report on initial margin transparency contain, and what broad areas do they address? | contains ten policy proposals. They cover three broad categories: (i) CCP transparency...(ii) governance and review of CCP initial margin models...(iii) clearing member transparency to clients and to CCPs | ten final policy proposals which aim to increase the resilience of the centrally cleared market ecosystem in times of market stress. | Contradictory; Contradictory; Pretextual |
| 2 | opus-47-websearch | What obligation does the final CPMI-IOSCO guidance place on CCPs to provide margin simulation tools, and to which participants must those tools be made available? | CCPs 'should consider' making margin simulation tools available to all clearing members, and where feasible their clients, including prospective clearing members and prospective clients, subject to appropriate non-disclosure agreements where necessary. | 2024 consultative: 'Margin simulation tools with certain minimum functionality should be made available by CCPs to clearing members and their clients.' | Contradictory; Contradictory; Pretextual |
| 3 | opus-47-websearch | How frequently must CCPs publicly disclose their initial margin responsiveness measure, and what observation periods and measurement horizons does the disclosure require? | quarterly basis for the most relevant products per clearing service. Two observation periods are required: a 3-month and a 12-month observation period. Within each period, the measure is reported as the largest change per single business day and the largest change per 20 business days | CCPs must disclose the responsiveness measure for the most relevant products per clearing service on a quarterly basis, reflecting the largest per business day and largest per 20 business days over 3-month and 12-month observation periods. | Contradictory; Contradictory; Pretextual |
| 4 | opus-47-websearch | What governance body at a CCP holds ultimate responsibility for the margin model override framework, and how frequently must independent validation of the margin system occur? | the CCP's board has ultimate responsibility for the margin model framework, including the override framework. The board must ensure that validation of the margin system and stress-testing framework (for both credit and liquidity risks) is conducted at least annually, and that this validation is inde | The board of a CCP should be ultimately responsible for any material change to the margin system, including establishing the framework for discretionary overrides. The board should have ultimate responsibility for ensuring that the validation...is conducted at least annually and in a manner that is  | Contradictory; Contradictory |
| 5 | opus-47-websearch | Which international standard-setting bodies bear responsibility for implementing each of the ten policy proposals in the January 2025 BCBS-CPMI-IOSCO initial margin report? | For proposals 1–8 (CCP-facing)...CPMI and IOSCO are the relevant standard-setting bodies...For proposals 9 and 10 (clearing-member-facing transparency)...BCBS is the relevant standard-setting body, since clearing members are predominantly bank-affiliated. | From the BIS press release of 6 May 2026: 'The final report contained ten policy proposals...For proposals 1–8, CPMI and IOSCO are the relevant standard-setting bodies.' (implies proposals 9–10 are BCBS) | Contradictory; Contradictory; Contradictory |
| 6 | opus-47-websearch | Where should comment letters for the CPMI-IOSCO 2026 initial margin consultation be submitted, and what is the deadline? | Comment letters...should be submitted by 30 June 2026. They should be sent by email to the CPMI Secretariat at cpmi@bis.org and to the IOSCO Secretariat at margin@iosco.org. | BIS landing page for the May 2026 consultative document: 'Comments must be submitted by 30 June 2026 via email to cpmi@bis.org and margin@iosco.org.' | Contradictory; Contradictory; Contradictory |
| 7 | opus-47-websearch | Which international standard-setting bodies co-authored the January 2025 report on streamlining variation margin and initial margin model responsiveness in non-centrally cleared markets? | co-authored by two standard-setting bodies: the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO). CPMI did NOT co-author this particular report, because the report covers non-centrally cleared markets (CPMI's remit is payment systems  | BIS landing page for the non-centrally cleared markets report: The report is authored by BCBS and IOSCO, CPMI is not listed as a co-author. | Contradictory; Pretextual; Contradictory |
| 8 | opus-47-websearch | By when are CCPs expected to implement the public quantitative disclosure amendments in the CPMI-IOSCO 2026 consultation, and is this timeline a binding requirement? | CPMI and IOSCO encourage CCPs to implement the changes to the PQDs within 12 months of the publication of the final report...expressed as an expectation/encouragement rather than a hard legal mandate | CPMI-IOSCO encourage CCPs to implement the changes to the PQDs within 12 months of publication of the final report. | Contradictory; Contradictory; Pretextual |
| 9 | sonnet-46-websearch | How many policy proposals does the January 2025 BCBS-CPMI-IOSCO report on initial margin transparency in centrally cleared markets contain, and what broad themes do they address? | contains 10 policy proposals. They fall into three broad categories explicitly named in the report: (1) CCP transparency... (2) Governance and review of initial margin models... (3) Clearing member transparency | ten final policy proposals which aim to increase the resilience of the centrally cleared market ecosystem in times of market stress. | Contradictory; Contradictory; Pretextual; Contradictory |
| 10 | sonnet-46-websearch | What level of obligation does the CPMI-IOSCO 2026 guidance place on CCPs for providing margin simulation tools, and to whom must those tools be made available? | The guidance uses 'should consider making' language: CCPs should consider making margin simulation tools available to all clearing members (CMs) and, where feasible, their clients | Margin simulation tools with certain minimum functionality should be made available by CCPs to clearing members and their clients. | Contradictory; Contradictory; Pretextual |
| 11 | sonnet-46-websearch | How frequently must CCPs disclose their initial margin responsiveness measure, and what observation periods and reporting metrics are required under the CPMI-IOSCO 2026 consultation? | CCPs should disclose the initial margin responsiveness measure on a quarterly basis... Two observation periods are required: a 3-month observation period and a 12-month observation period... largest margin change per business day, and (ii) the largest margin change per 20 business days | CCPs must disclose the responsiveness measure for the most relevant products per clearing service on a quarterly basis, reflecting the largest per business day and largest per 20 business days over 3-month and 12-month observation periods. | Contradictory; Pretextual; Contradictory |
| 12 | sonnet-46-websearch | Which governance body at a CCP holds ultimate responsibility for the margin model override framework under the CPMI-IOSCO 2026 guidance, and what is the minimum required frequency for model validation? | the CCP's board of directors bears ultimate responsibility for the margin model override framework... the board should ensure that validation... is conducted at least annually, and in a manner that is independent | The board of a CCP should be ultimately responsible for any material change to the margin system, including establishing the framework for discretionary overrides... validation... conducted at least annually and in a manner that is independent | Contradictory; Pretextual; Contradictory |
| 13 | sonnet-46-websearch | What specific information must CCPs publicly disclose about their margin model override framework under the CPMI-IOSCO 2026 consultation on initial margin transparency? | (1) the instances or circumstances where overrides may be warranted; (2) the key decision-makers authorised to exercise override discretion; and (3) the permissible types of adjustments that can be made. | 'CCPs should publicly disclose relevant information on their override framework.' [Confirmed via multiple search snippets of d232 content] | Contradictory; Contradictory; Pretextual |
| 14 | sonnet-46-websearch | Which standard-setting bodies are responsible for implementing each of the ten policy proposals in the January 2025 BCBS-CPMI-IOSCO initial margin transparency report? | Proposals 1–8 are directed at CCPs and are to be implemented by CPMI and IOSCO... Proposals 9–10 address clearing member transparency obligations... the BCBS is the relevant implementing body for these proposals | The final report contained ten policy proposals relating to transparency and responsiveness of centrally cleared initial margin. For proposals 1–8, CPMI and IOSCO are the relevant standard-setting bodies. | Contradictory; Contradictory; Pretextual |
| 15 | sonnet-46-websearch | Where should comments on the CPMI-IOSCO 2026 initial margin consultation be submitted, and by what deadline? | Comment letters for the CPMI-IOSCO May 2026 consultation (d232) must be submitted by 30 June 2026. Submissions should be sent by email simultaneously to two secretariats: the CPMI Secretariat at cpmi@bis.org and the IOSCO Secretariat at margin@iosco.org. | Comments must be submitted by 30 June 2026 via email to cpmi@bis.org and margin@iosco.org. | Contradictory; Contradictory; Contradictory |
| 16 | sonnet-46-websearch | Which international standard-setting bodies co-authored the January 2025 report on streamlining variation margin and initial margin model responsiveness in non-centrally cleared derivatives markets? | The January 2025 report titled 'Streamlining variation margin processes and initial margin responsiveness of margin models in non-centrally cleared markets' was co-authored by the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO). CPMI | BIS landing page for the non-centrally cleared markets report: authored by BCBS and IOSCO, CPMI is not listed as a co-author. | Contradictory; Pretextual; Contradictory |
| 17 | sonnet-46-websearch | What implementation timeline does the CPMI-IOSCO 2026 consultation set for CCP adoption of the Public Quantitative Disclosure amendments, and is that timeline binding? | CPMI-IOSCO 'encourage' CCPs to implement the changes to the PQD standards within 12 months of publication of the final report. This timeline is explicitly non-mandatory, the word used is 'encourage' rather than 'require', 'must', or 'shall'. | CPMI-IOSCO encourage CCPs to implement the changes to the PQDs within 12 months of publication of the final report. | Contradictory; Contradictory; Pretextual |

---

_Published: 2026-06-07T07:58:36.315560+00:00_

## Related concepts

- Regulation: [CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026](/okf/regulations/CPMI-IOSCO-INITIAL-MARGIN-DISCLOSURE-CONSULT-2026.md)
- Regulator: [BIS-CPMI-INT-001](/okf/bodies/BIS-CPMI-INT-001.md)
- Methodology: [v2.3](/okf/methodology.md)