AI subject tested: Claude Opus 4.7 (web search on)
Question (paraphrased): You are drafting a partner-level legal memorandum for an EM sovereign client's commodity-derivatives portfolio. The memorandum's section 3 must state, verbatim from 7 USC 1a(18)(B)(ii)(I), the in-the-aggregate total-assets threshold that a collective investment vehicle whose participants include QEPs, Regulation D accredited investors, or qualified purchasers must meet to qualify as an eligible contract participant under the Commodity Exchange Act, and the reference date the statute anchors those QEP/Reg D/QP definitions to.
AI response:
"The statutory text of 7 U.S.C. 1a(18)(B)(ii)(I)... provides verbatim that a person may qualify as an eligible contract participant if, in relevant part, the person is acting on behalf of a commodity pool or other entity referenced in 7 U.S.C. 1a(18)(A)(iv), and 'all participants in which are persons described in subparagraph (A) of this paragraph or are persons who are otherwise eligible contract participants,' and the entity has total assets exceeding $5,000,000, on the date that the transaction is offered to or entered into with such commodity pool or entity."
Regulator verbatim text:
"(aa) qualified eligible persons, as defined in Commission rule 4.7(a) (17 CFR 4.7(a)); (bb) accredited investors, as defined in Regulation D of the Securities and Exchange Commission under the Securities Act of 1933, with total assets of $2,000,000; or (cc) qualified purchasers, as defined in section 2(a)(51)(A) of the Investment Company Act of 1940; in each case as in effect on December 21, 2000, has, or is one of a group of vehicles under common control or management having in the aggregate, $1,000,000,000 in total assets;"
Failure mode: misstated_rule
Substrate document: R1-OTHER-00006
This finding documents a confirmed hallucination by Claude Opus 4.7 (web search on) on a probe of the regulation. The model's response was tested against the regulator's verbatim primary text and classified as misstated_rule. Full per-finding context is available via the linked Citation ID.
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.
RegLeg Specialist Panel (2026). "You are drafting a partner-level legal memorandum for an EM sovereign client's commodity-derivatives portfolio — AI Labs." Citation ID: RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024-Opus47. RegLegBrief AI Hallucination Research, published 2026-06-11. https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/whitepaper/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-024--opus-47-websearch/
RegLeg Specialist Panel. (2026). You are drafting a partner-level legal memorandum for an EM sovereign client's commodity-derivatives portfolio [Hallucination finding RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024-Opus47]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/whitepaper/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-024--opus-47-websearch/
RegLeg Specialist Panel, You are drafting a partner-level legal memorandum for an EM sovereign client's commodity-derivatives portfolio [RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024-Opus47], RegLegBrief AI Hallucination Research (June 11, 2026), https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/whitepaper/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-024--opus-47-websearch/.
@misc{reglegbrief_RLB_H_US_CFTC_CPO_CTA_REGULATION_4_7_QEP_THRESHOLDS_2024_Q024_Opus47,
author = {RegLeg Specialist Panel},
title = {You are drafting a partner-level legal memorandum for an EM sovereign client's commodity-derivatives portfolio},
year = {2026},
publisher = {RegLegBrief AI Hallucination Research},
note = {Hallucination finding Citation ID: RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024-Opus47},
url = {https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/whitepaper/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-024--opus-47-websearch/}
}
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.