{ "tool_id": "art-510-build-art5-diligence-evidence", "tool_version": "1.0.0", "display_name": "Article 5 Due Diligence Evidence Record", "mcp_name": "build_art5_diligence_evidence", "mandate_type": "compliance_mandate", "wave": 78, "gpu": false, "url": "https://ainumbers.co/chaingraph/art-510-build-art5-diligence-evidence.html", "description": "Records, for one securitisation position over one stated period, which Article 5 verification and ongoing monitoring duties an institutional investor declares it performed, the evidence references behind each, what remains outstanding, and the accountability trail naming who signed each off. Each duty carries a pinned citation object with a full date from which the provision was in force: a bare four digit year is rejected and named rather than accepted, and a superseded citation is recorded through a superseding reference and is never stripped. Where a duty turns on a question the facts do not settle, the record names what is undetermined, which input resolves it and who decides, rather than raising a bare flag. Gaps are published as a named list with the duty against each one and never as a coverage ratio, a percentage of duties met or a score, because a proportion invites a reader to treat a partial record as partial compliance. A duty reaches performed only when it is declared performed, names evidence, and carries records naming a performer and an approver by distinct identity, each bound to its own signing identity; an unsigned record holds the duty rather than passing it, an agent identity satisfies a human role only under an explicit human role mandate, and a time boxed override never satisfies a sign off here because no clock is read. The duty set shipped is the Article 5 paragraph set, which is primary legislation rather than a maintained template, and it is not presented as exhaustive: a caller may declare further duties carrying their own pinned citations. No disclosure template is read, validated or asserted, and the record works on opaque position, deal and identity references and on evidence references rather than evidence content, so no loan level or personal data is needed. Stated boundary: every status is evidence of a human act. Nothing here states that the diligence performed was adequate, that a duty was discharged to any supervisor satisfaction, or that any authority has accepted anything, and it is not a filing.", "input_schema_ref": "chaingraph/art-510-build-art5-diligence-evidence.html#manifest", "consumes": [ "art-509-recompute-payment-waterfall" ], "feeds": [], "status": "live", "conformance_fixtures": true, "compute_capability": "server", "compute_images": [ { "system": "sha256-source", "image_id": "sha256:72798cbb71379e42e0b388c97b0781d1189fd20a06e289e2bbff86254b0dd17e", "valid_from": "2026-07-10" }, { "system": "risc0", "image_id": "sha256:a1a0bc89b5b1febaeda3519f6dbade0fa5ac16beeb143c4e1b01689573567bc6", "valid_from": "2026-08-01" } ], "compute_proof_ready": "ready", "export_capability": [ "json" ], "compute_proof": { "type": "ZkVmReceipt", "system": "risc0", "receiptFormat": "groth16-bn254", "imageId": "sha256:a1a0bc89b5b1febaeda3519f6dbade0fa5ac16beeb143c4e1b01689573567bc6", "seal": "AljYChzZedxh9+Ba33VdAXxg6iGHe25nKu3qih7cE9gLoebsjK1nVt/rSLF/regO/ltpuAeUql6gETxM1EEoFRzlz5AUK70b6Wf4BeM5BHlyyamiIA/MH/QSCxrHr9P7H+3sayvq0NxNj596fAO0MCH5JKBtpSRdh3nl77JACNEiWpIwPjWB4cBydQy6qI59hk8pR/C+JGOD8jzGBgGOWRxgSNjyj+/v86RV4qNUH1rhbOlDlAMtAsU4mtg9VNGzDqPfkzoMi2Iz02DBvsyDiHqU41oau89Bdx0ha/w05DwnXLhsAlqZEln4rnML7TZ9pBhzfR4UQThDyyoWkjBtCg==", "journal": { "chaingraph_version": "0.4.0", "kernel_digest": "sha256:72798cbb71379e42e0b388c97b0781d1189fd20a06e289e2bbff86254b0dd17e", "output": { "agent_parity_findings": [ { "code": "ART5_AGENT_WITHOUT_HUMAN_ROLE_MANDATE", "detail": "An agent identity filed this sign-off and carries no explicit human-role mandate, so under SPEC.md §27.8 it does not satisfy the role. The record is carried and is not counted toward the trail.", "duty_id": "monitor_ongoing_performance", "identity_id": "did:example:agent-1", "role": "approver" } ], "citations": { "art5_1_a_credit_granting": { "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_c_risk_retention": { "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_e_disclosure": { "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_3_risk_assessment": { "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_b_stress_testing": { "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_d_internal_reporting": { "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_ongoing_monitoring": { "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art7_investor_report": { "id": "Regulation (EU) 2017/2402 Article 7(1)(e)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" } }, "deal_ref": "SYNTH-2025-A", "distinctness_basis": "Roles count DISTINCT identity.id (SPEC.md §27.3), never records and never signing keys. One human rotating keys, or signing twice, counts once.", "duty_count": 7, "duty_results": [ { "accountability_trail": { "by_role": { "approver": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "approver", "status": "hold", "unsigned_approval_count": 0 }, "performer": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "duty_class": "verification_before_holding", "duty_id": "verify_credit_granting_standards", "evidence": [], "evidence_count": 0, "judgment_required": null, "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "performed_asserted": false, "performed_note": null, "position": 1, "status": "outstanding", "status_basis": "The investor has not declared this duty performed for this position and period. Absent evidence holds; nothing here treats silence as performance.", "typical_evidence": "The originator credit policy, and the investor record of the comparison made against its non-securitised book." }, { "accountability_trail": { "by_role": { "approver": { "approval_count": 1, "counted_identities": [ "did:example:officer-b" ], "counted_identity_count": 1, "reason": "At least one signed record names a distinct identity in this role on this duty.", "rejection_count": 0, "role": "approver", "status": "satisfied", "unsigned_approval_count": 0 }, "performer": { "approval_count": 1, "counted_identities": [ "did:example:analyst-a" ], "counted_identity_count": 1, "reason": "At least one signed record names a distinct identity in this role on this duty.", "rejection_count": 0, "role": "performer", "status": "satisfied", "unsigned_approval_count": 0 } }, "duty_id": "verify_risk_retention", "record_count": 2, "required_roles": [ "performer", "approver" ], "roles_required_count": 2, "roles_satisfied_count": 2, "status": "satisfied" }, "citation": { "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "decided_by": "The investor function that performed the retention verification. This tool does not decide it.", "duty_class": "verification_before_holding", "duty_id": "verify_risk_retention", "evidence": [ { "dated": "2025-07-05", "description": "Retention statement in the transaction documents naming the retention holder and the form relied on.", "evidence_ref": "EV-RET-1", "evidence_type": "transaction_document", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "label": "Verify that the originator, sponsor or original lender retains a material net economic interest of not less than 5 percent and discloses it to institutional investors.", "performed_asserted": true, "performed_note": null, "position": 2, "status": "performed", "status_basis": "The duty is declared performed, evidence is named, and a conformant signed record names both a performer and an approver by distinct identity. This records evidence of a human act. It is not a statement that what was done was adequate.", "typical_evidence": "The retention statement in the transaction documents, the retention holder identity, and the retention form relied on." }, { "accountability_trail": { "by_role": { "approver": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "approver", "status": "hold", "unsigned_approval_count": 0 }, "performer": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "performer", "status": "hold", "unsigned_approval_count": 0 } }, "duty_id": "verify_article_7_disclosure", "record_count": 0, "required_roles": [ "performer", "approver" ], "roles_required_count": 2, "roles_satisfied_count": 0, "status": "hold" }, "citation": { "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "decided_by": "The investor function that obtained the information. This tool does not decide it.", "duty_class": "verification_before_holding", "duty_id": "verify_article_7_disclosure", "evidence": [], "evidence_count": 0, "judgment_required": null, "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "performed_asserted": false, "performed_note": null, "position": 3, "status": "outstanding", "status_basis": "The investor has not declared this duty performed for this position and period. Absent evidence holds; nothing here treats silence as performance.", "typical_evidence": "The reference to where the information was made available, and the investor record of having obtained it. Availability is what is verified; the content of any disclosure template is not assessed here." }, { "accountability_trail": { "by_role": { "approver": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "approver", "status": "hold", "unsigned_approval_count": 0 }, "performer": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "performer", "status": "hold", "unsigned_approval_count": 0 } }, "duty_id": "assess_risk_characteristics", "record_count": 0, "required_roles": [ "performer", "approver" ], "roles_required_count": 2, "roles_satisfied_count": 0, "status": "hold" }, "citation": { "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "decided_by": "The investor function that carried out the assessment. This tool does not decide it.", "duty_class": "assessment_before_holding", "duty_id": "assess_risk_characteristics", "evidence": [], "evidence_count": 0, "judgment_required": null, "label": "Carry out a due-diligence assessment enabling the risks of the position to be assessed, covering the risk characteristics of the position and of the underlying exposures, and the structural features of the transaction.", "performed_asserted": false, "performed_note": null, "position": 4, "status": "outstanding", "status_basis": "The investor has not declared this duty performed for this position and period. Absent evidence holds; nothing here treats silence as performance.", "typical_evidence": "The written pre-investment assessment, and the source data and structural analysis it rests on." }, { "accountability_trail": { "by_role": { "approver": { "approval_count": 1, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "approver", "status": "hold", "unsigned_approval_count": 0 }, "performer": { "approval_count": 1, "counted_identities": [ "did:example:analyst-a" ], "counted_identity_count": 1, "reason": "At least one signed record names a distinct identity in this role on this duty.", "rejection_count": 0, "role": "performer", "status": "satisfied", "unsigned_approval_count": 0 } }, "duty_id": "monitor_ongoing_performance", "record_count": 2, "required_roles": [ "performer", "approver" ], "roles_required_count": 2, "roles_satisfied_count": 1, "status": "hold" }, "citation": { "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it.", "duty_class": "ongoing_monitoring", "duty_id": "monitor_ongoing_performance", "evidence": [ { "dated": "2025-09-30", "description": "Waterfall recomputation for the period, produced by art-509 from the period investor report and the priority ladder.", "evidence_ref": "EV-MON-1", "evidence_type": "recomputation", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "label": "Establish written procedures to monitor, on an ongoing basis and for the life of the position, the performance of the position and of the underlying exposures.", "performed_asserted": true, "performed_note": null, "position": 5, "status": "evidence_unsigned", "status_basis": "The duty is declared performed and evidence is named, but the accountability trail is not satisfied, so no conformant signed record shows who stands behind it.", "typical_evidence": "The written monitoring procedure, and the monitoring output for this period, including any waterfall recomputation performed on the period investor report." }, { "accountability_trail": { "by_role": { "approver": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "approver", "status": "hold", "unsigned_approval_count": 0 }, "performer": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "performer", "status": "hold", "unsigned_approval_count": 0 } }, "duty_id": "perform_stress_tests", "record_count": 0, "required_roles": [ "performer", "approver" ], "roles_required_count": 2, "roles_satisfied_count": 0, "status": "hold" }, "citation": { "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "decided_by": "The investor risk function that owns the stress testing. This tool does not decide it.", "duty_class": "ongoing_monitoring", "duty_id": "perform_stress_tests", "evidence": [], "evidence_count": 0, "judgment_required": { "decided_by": "The investor risk committee.", "named_completely": true, "resolving_input": "The risk committee proportionality determination recorded for this position.", "what_is_undetermined": "Whether a quarterly stress test is proportionate to the risk of this position, given its seniority and the size of the holding." }, "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "performed_asserted": false, "performed_note": null, "position": 6, "status": "judgment_required", "status_basis": "The caller declared that this duty turns on a question the facts supplied do not settle. What is undetermined, which input resolves it, and who decides are all named.", "typical_evidence": "The stress test run for this period, its assumptions, and the record of who ran it." }, { "accountability_trail": { "by_role": { "approver": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "approver", "status": "hold", "unsigned_approval_count": 0 }, "performer": { "approval_count": 0, "counted_identities": [], "counted_identity_count": 0, "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass.", "rejection_count": 0, "role": "performer", "status": "hold", "unsigned_approval_count": 0 } }, "duty_id": "report_internally", "record_count": 0, "required_roles": [ "performer", "approver" ], "roles_required_count": 2, "roles_satisfied_count": 0, "status": "hold" }, "citation": { "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_at": "2026-07-31", "mapped_by": "AINumbers SECZ-K-1", "scheme": "eu-regulation", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it.", "duty_class": "ongoing_monitoring", "duty_id": "report_internally", "evidence": [], "evidence_count": 0, "judgment_required": null, "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "performed_asserted": false, "performed_note": null, "position": 7, "status": "outstanding", "status_basis": "The investor has not declared this duty performed for this position and period. Absent evidence holds; nothing here treats silence as performance.", "typical_evidence": "The internal report covering this position and period, and the record of it reaching the management body." } ], "duty_set": { "duty_set_id": "EU-SECR-ART5-PARAGRAPHS", "duty_set_label": "The duties stated in Article 5 of Regulation (EU) 2017/2402, as amended by Regulation (EU) 2021/557", "exhaustive": false, "exhaustiveness_note": "This is the Article 5 paragraph set, not a maintained template or field set, and it is not presented as an exhaustive statement of everything an institutional investor must do. A caller may declare additional duties carrying their own pinned citations.", "field_set_version": "1.0.0", "shipped_duty_count": 7 }, "investor_ref": "INV-SYNTH-1", "judgment_duties": [ { "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "decided_by": "The investor risk committee.", "duty_id": "perform_stress_tests", "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "resolving_input": "The risk committee proportionality determination recorded for this position.", "what_is_undetermined": "Whether a quarterly stress test is proportionate to the risk of this position, given its seniority and the size of the holding." } ], "no_adequacy_claim": "Every status recorded here is evidence OF a human act. Nothing here states that the diligence performed was adequate, that a duty was discharged to any supervisor satisfaction, or that any regulator has accepted anything.", "no_ratio_published": "This artifact publishes counts and a named gap list. It deliberately publishes no coverage ratio, no percentage of duties met and no score, because a proportion invites a reader to treat a partial record as partial compliance.", "not_a_filing": "This is an evidence record assembled for the investor own file. It is not a regulatory filing, it is not submittable to any competent authority, and it does not discharge Article 5.", "note": "Deterministic Article 5 due-diligence evidence record for one securitisation position over one stated period. Single-run and stateless: it holds no records, runs on no schedule, and retains nothing. It records which duties the investor declares performed, the evidence references behind each, what remains outstanding as a named gap list, and the §27 accountability trail naming who signed each off. It performs none of the duties, recomputes no underlying arithmetic, reads no disclosure template, publishes no coverage ratio, and expresses no view on whether the diligence was adequate. It is not a filing and not legal advice.", "outstanding_duties": [ { "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it.", "duty_id": "verify_credit_granting_standards", "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period." }, { "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "decided_by": "The investor function that obtained the information. This tool does not decide it.", "duty_id": "verify_article_7_disclosure", "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period." }, { "citation_id": "Regulation (EU) 2017/2402 Article 5(3)", "decided_by": "The investor function that carried out the assessment. This tool does not decide it.", "duty_id": "assess_risk_characteristics", "label": "Carry out a due-diligence assessment enabling the risks of the position to be assessed, covering the risk characteristics of the position and of the underlying exposures, and the structural features of the transaction.", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period." }, { "citation_id": "Regulation (EU) 2017/2402 Article 5(4)", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it.", "duty_id": "monitor_ongoing_performance", "label": "Establish written procedures to monitor, on an ongoing basis and for the life of the position, the performance of the position and of the underlying exposures.", "status": "evidence_unsigned", "what_is_missing": "The duty names evidence but no conformant signed record satisfies both required roles." }, { "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it.", "duty_id": "report_internally", "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period." } ], "override_handling": "A §27.5 override is time-boxed and its expiry can only be judged against an instant. This kernel reads no clock, so an override record NEVER satisfies a sign-off here and is reported instead. On expiry an override lapses and the underlying policy reverts; it can never become a silent permanent auto-pass through this surface.", "override_record_count": 0, "performed_count": 1, "period": { "bounds_present": true, "end_date": "2025-09-30", "label": "2025-Q3", "order_valid": true, "start_date": "2025-07-01" }, "position_ref": "POS-SYNTH-1", "rationale": [ "Article 5 due-diligence evidence recorded for position POS-SYNTH-1 on deal SYNTH-2025-A, held by investor INV-SYNTH-1, for period 2025-Q3 running 2025-07-01 to 2025-09-30.", "7 duties are recorded: the 7 Article 5 paragraph duties shipped with this tool, plus 0 declared by the caller. The shipped set is the Article 5 paragraph set and is never presented as an exhaustive statement of everything an investor must do.", "1 of the 7 duties carry a performance declaration, named evidence, and a signed record naming both a performer and an approver by distinct identity.", "5 duties are outstanding, each named in the gap list with what is missing against it. No proportion or coverage figure is published anywhere in this artifact, because a percentage would invite a reader to treat a partial record as partial compliance.", "1 duty turns on a question the facts supplied do not settle. Each names what is undetermined, which input resolves it, and who decides, rather than carrying a bare flag.", "Every status here is evidence of a human act. Nothing in this artifact states that the diligence performed was adequate, that any duty was discharged to a supervisor satisfaction, or that any regulator has accepted anything. Those are for the investor and its supervisor.", "No Article 7 disclosure template is read, validated or asserted anywhere in this tool. Where a duty concerns Article 7 information, what is recorded is that the information was obtained, never an assessment of a template field set." ], "rejected_citations": [] } } } }