Practitioners — Lawyers · updated 2026-06-11

Finding#3 . NPRM-stage CPI-U buying-power figures invented

RLB Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011

What the RLB Specialist Panel found

Finding#3 . NPRM-stage CPI-U buying-power figures invented

Citation ID: RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011-Sonnet46
AI's failure: AI invented February-2023 buying-power figures that the NPRM does not record
Risk for the Lawyers: Operational decision-support exposure on testimony, technical notes, and economist deliverables that quote AI-supplied CPI-U figures For lawyers working on CFTC Regulation 4.7 matters, the AI's stated answer reads as a verbatim quotation that a practitioner would paste into a memo, register entry, or client deliverable before verification against the source. The regulator's own text, however, records a different position. The NPRM pre-print PDF records, using CPI-U data as of February 2023, that the $2,000,000 threshold in the Securities Portfolio Test has the same buying power as approximately $4,270,000, and the $200,000 threshold in the Initial Margin and Premiums Test has the same buying power as approximately $427,000. Sonnet 4.6 reported $4,070,000 and $407,000 for the same reference month. The 5 percent gap between the AI's figures and the regulator's stated figures cannot be reconciled to any CPI-U release; the answer is invented under the appearance of a precise quotation. For a lawyer drafting on this question, the immediate risk is that the AI's answer enters a client memo, board briefing, or transactional opinion without verification, and that the inconsistency surfaces later under counterparty review, regulatory inquiry, or internal QC.
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References — raw findings (per AI model)

RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011-Sonnet46 Claude Sonnet 4.6 (web search on)

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Cite this finding

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.

RLB Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, Finding#3 . NPRM-stage CPI-U buying-power figures invented [RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011], RegLegBrief AI Hallucination Research (June 11, 2026), https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/practitioners/lawyers/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-011/.

Plain text Download

RegLeg Specialist Panel (2026). "Finding#3 . NPRM-stage CPI-U buying-power figures invented — Practitioners — Lawyers." Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011. RegLegBrief AI Hallucination Research, published 2026-06-11. https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/practitioners/lawyers/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-011/

APA 7th edition Download

RegLeg Specialist Panel. (2026). Finding#3 . NPRM-stage CPI-U buying-power figures invented [Hallucination finding RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/practitioners/lawyers/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-011/

BibTeX Download

@misc{reglegbrief_RLB_F_US_CFTC_CPO_CTA_REGULATION_4_7_QEP_THRESHOLDS_2024_Q011,
  author    = {RegLeg Specialist Panel},
  title     = {Finding#3 . NPRM-stage CPI-U buying-power figures invented},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q011},
  url       = {https://reglegbrief.com/regulators/j3/us/cftc/cpo-cta-regulation-4-7-qep-thresholds-2024/practitioners/lawyers/finding/US-CFTC-US-001-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-v1-011/}
}

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