--- type: "AILabsWhitepaper" title: "Hallucination findings: Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants" slug: "SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025-general-v1" audience: "general" regulation_slug: "SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025" regulation_id: "1834" body_id: "CFTC-US-001" jurisdiction_code: "US" j_level: "J3" regulator_short_code: "CFTC" methodology_version: "2.0" substrate_version: 1 generated_at: "2026-06-03T21:50:35.811432+00:00" published_at: "2026-06-03T21:50:35.811432+00:00" license: "CC-BY-4.0" resource: "https://reglegbrief.com/regulators/j3/us/cftc/SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025/ai-labs/" timestamp: "2026-06-16T00:00:00+00:00" --- # Hallucination findings: Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants - **Regulation.** [`SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025`](/okf/regulations/SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025.md) — Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants - **Regulator.** [`CFTC-US-001`](/okf/bodies/CFTC-US-001.md) - **Audience.** general - **Methodology.** 2.0 - **Generated.** 2026-06-03T21:50:35.811432+00:00 ## Full whitepaper # Hallucination findings, Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants _Jurisdiction: US ; Body: CFTC-US-001 ; Regulation: SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025_ 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 | Which specific appendix to 17 CFR Part 23 Subpart H was inadvertently removed by the December 2025 final rule and restored by the January 28, 2026 correction, and what guidance does it contain? | On January 28, 2026, the Commission published a correction to the final rule (Doc. 2026-01712, also effective Jan. 29, 2026) that reinstated an appendix that would otherwise have been inadvertently removed by the December 30 amendatory instructions. | Appendix A to subpart H: 'Guidance on the Application of §§23.434 and 23.440 for Swap Dealers That Make Recommendations to Counterparties or Special Entities.' This appendix has been present since 2012. | Contradictory; Contradictory; Contradictory; Contradictory; Fabricated | | 2 | opus-47-websearch | What trading venues does CFTC Staff Letter 25-49 specifically address for the treatment of intended-to-be-cleared swaps, and which prior no-action letter does it supersede in its entirety? | (i) swaps that the parties intend to clear contemporaneously with execution ('ITBC swaps') where the swap dealer does not know the identity of its counterparty pre-execution, and (ii) ITBC swaps initiated on a swap execution facility or designated contract market. | CFTC Staff Letter 25-49 provides market participants certainty with respect to the treatment of ITBC Swaps (Intended-to-be-Cleared Swaps) initiated on an Eligible UK Trading Venue. | Contradictory; Contradictory; Contradictory; Pretextual | | 3 | opus-47-websearch | 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? | 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. | 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 | Contradictory; Contradictory; Contradictory; Contradictory; Contradictory; Contradictory | | 4 | sonnet-46-websearch | A partner-level client advisory on the December 2025 CFTC swap dealer rulemaking package is asked to cover the January 2026 correction notice. Which specific appendix was accidentally removed by the final rule as published, and what guidance does it contain? | The correction rectified a drafting error that would have unintentionally removed an appendix to the Commission's regulations that was not intended to be altered. The correction does not affect the substantive provisions of the rule. | Appendix A to subpart H: 'Guidance on the Application of §§23.434 and 23.440 for Swap Dealers That Make Recommendations to Counterparties or Special Entities.' This appendix has been present since 2012. The Final Rule was not intended to alter appendix A in any way. | Contradictory; Contradictory; Contradictory; Contradictory; Contradictory; Pretextual | --- _Published: 2026-06-03T21:50:35.657469+00:00_ ## Related concepts - Regulation: [SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025](/okf/regulations/SWAP-DEALER-BUSINESS-CONDUCT-DOCUMENTATION-2025.md) - Regulator: [CFTC-US-001](/okf/bodies/CFTC-US-001.md) - Methodology: [v2.3](/okf/methodology.md)