4 finding cards across
2 AI Models —
covering 4 Response Hallucinations +
21 Citation Hallucinations
(25 hallucination failures total).
Each card pairs the AI's answer against the authenticated regulator-text excerpt that contradicts it, and flags every AI-cited source as Fabricated / Pretextual / Contradictory.
Model: Claude Opus 4.7 (web search on)
· published 2026-06-03
· Misstated Rule
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?
Claude Opus 4.7 (web search on) answered
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.
Regulator text says
Appendix A to Subpart H of Part 23 — Guidance on the Application of §§ 23.434 and 23.440 for Swap Dealers That Make Recommendations to Counterparties or Special Entities. The following provides guidance on the application of §§ 23.434 and 23.440 to swap dealers that make recommendations to counterparties or Special Entities.
Verbatim source
17cfr-part-23-subpart-h-ecfr-2026-06-08.pdf — 17 CFR Appendix A to Subpart H of Part 23
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?
Claude Opus 4.7 (web search on) answered
(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.
Regulator text says
Consequently, MPD issued CFTC Staff Letter 23-01, which superseded CFTC Staff Letter 13-70 in its entirety. CFTC Staff Letter 23-01 provided a revised MPD no-action position, which incorporates, expands on, and refines the MPD no-action position presented in CFTC Staff Letter 13-70 with regard to compliance with certain External Business Conduct Standards by Swap Entities, and clarifies its no-action position regarding documentation requirements under the STRD Requirement.
Verbatim source
cftc-final-rule-2025-23953-fr-90fr61226.pdf — Federal Register Vol. 90 No. 246 at 61227, fn. 33
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?
Claude Opus 4.7 (web search on) answered
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 text says
the Commission is eliminating the PTMMM Requirement in its entirety as proposed 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. [Combined with 23.431(c) exceptions: "Paragraph (a) of this section shall not apply with respect to a transaction that is: (1) Initiated on a designated contract market; (2) Initiated with a counterparty whose identity is not known to the swap entity prior to execution on a swap execution facility..."]
Verbatim source
cftc-final-rule-2025-23953-fr-90fr61226.pdf — Federal Register Vol. 90 No. 246 at 61231 (PTMMM elimination scope) and 17 CFR § 23.431(c)
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?
Claude Sonnet 4.6 (web search on) answered
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.
Regulator text says
Appendix A to Subpart H of Part 23 — Guidance on the Application of §§ 23.434 and 23.440 for Swap Dealers That Make Recommendations to Counterparties or Special Entities. The following provides guidance on the application of §§ 23.434 and 23.440 to swap dealers that make recommendations to counterparties or Special Entities.
Verbatim source
17cfr-part-23-subpart-h-ecfr-2026-06-08.pdf — 17 CFR Appendix A to Subpart H of Part 23
Every finding on this page compares an AI subject's account of the rule
against the regulator's verbatim text from the regulator's own portal.
Both are linked. Each delta, its root causes, and impact analysis are
documented and published with immutable Citation IDs.