Practitioners — Lawyers · Last updated 11 Jun 2026 · Hallucination Register

Finding#10 . Wrong total-assets threshold in 7 USC 1a(18)(B)(ii)(I) for collective investment vehicles

RLB Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024

What the RLB Specialist Panel found

Finding#10 . Wrong total-assets threshold in 7 USC 1a(18)(B)(ii)(I) for collective investment vehicles

Citation ID: RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024-Opus47
AI's failure: AI misstated the statutory total-assets threshold for the ECP-eligible collective investment vehicle test
Risk for the Lawyers: Direct legal-opinion exposure on partner-level memos that recite an incorrect statutory threshold for ECP qualification 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. 7 USC 1a(18)(B)(ii)(I) provides that a collective investment vehicle qualifies as an eligible contract participant where each participant is a QEP, accredited investor, or qualified purchaser (in each case as in effect on December 21, 2000) and the vehicle 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. Opus 4.7 reported the threshold as $5,000,000. The misstatement is by a factor of two hundred. A partner-level legal memorandum that recites this incorrect threshold and then advises on counterparty eligibility on EM-sovereign commodity-derivatives transactions is directly exposed: an ineligible counterparty acting on the AI-stated $5M threshold may be transacting outside the statutory ECP safe harbour. 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-Q024-Opus47 Claude Opus 4.7 (web search on)
RLB-H-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024-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-Q024

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, Finding#10 . Wrong total-assets threshold in 7 USC 1a(18)(B)(ii)(I) for collective investment vehicles [RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024], 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-v1-024/.

Plain text Download

RegLeg Specialist Panel (2026). "Finding#10 . Wrong total-assets threshold in 7 USC 1a(18)(B)(ii)(I) for collective investment vehicles — Practitioners — Lawyers." Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024. 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-v1-024/

APA 7th edition Download

RegLeg Specialist Panel. (2026). Finding#10 . Wrong total-assets threshold in 7 USC 1a(18)(B)(ii)(I) for collective investment vehicles [Hallucination finding RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024]. 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-v1-024/

BibTeX Download

@misc{reglegbrief_RLB_F_US_CFTC_CPO_CTA_REGULATION_4_7_QEP_THRESHOLDS_2024_Q024,
  author    = {RegLeg Specialist Panel},
  title     = {Finding#10 . Wrong total-assets threshold in 7 USC 1a(18)(B)(ii)(I) for collective investment vehicles},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-US-CFTC-CPO-CTA-REGULATION-4-7-QEP-THRESHOLDS-2024-Q024},
  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-v1-024/}
}

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