{ "tool_id": "art-510-build-art5-diligence-evidence", "note": "Vectors computed directly from the shipped kernel. Every position, deal, identity and evidence reference here is SYNTHETIC. Covers a mixed record with a named gap list, a fully signed record, the bare-year citation rejection, a judgment_required duty naming what is undetermined and who decides, and the finite gate on an empty declaration set.", "vectors": [ { "name": "mixed-record-with-named-gap-list", "description": "Some duties performed and signed, one turning on a judgment the facts do not settle, one signed only by an agent identity with no human-role mandate, and the rest outstanding. The gaps are a named list, never a proportion.", "policy_parameters": { "position_ref": "POS-SYNTH-1", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2025-Q3", "start_date": "2025-07-01", "end_date": "2025-09-30" }, "duty_declarations": [ { "duty_id": "verify_risk_retention", "performed": true, "evidence": [ { "evidence_ref": "EV-RET-1", "evidence_type": "transaction_document", "description": "Retention statement in the transaction documents naming the retention holder and the form relied on.", "dated": "2025-07-05" } ] }, { "duty_id": "monitor_ongoing_performance", "performed": true, "evidence": [ { "evidence_ref": "EV-MON-1", "evidence_type": "recomputation", "description": "Waterfall recomputation for the period, produced by art-509 from the period investor report and the priority ladder.", "dated": "2025-09-30" } ] }, { "duty_id": "perform_stress_tests", "judgment_required": { "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.", "resolving_input": "The risk committee proportionality determination recorded for this position.", "decided_by": "The investor risk committee." } } ], "accountability_records": [ { "duty_id": "verify_risk_retention", "role": "performer", "record_type": "approval", "identity": { "id": "did:example:analyst-a", "actor_type": "human" }, "audit_signature": { "proof": { "cryptosuite": "eddsa-jcs-2022", "verificationMethod": "did:example:analyst-a#key-1" } } }, { "duty_id": "verify_risk_retention", "role": "approver", "record_type": "approval", "identity": { "id": "did:example:officer-b", "actor_type": "human" }, "audit_signature": { "proof": { "cryptosuite": "eddsa-jcs-2022", "verificationMethod": "did:example:officer-b#key-1" } } }, { "duty_id": "monitor_ongoing_performance", "role": "performer", "record_type": "approval", "identity": { "id": "did:example:analyst-a", "actor_type": "human" }, "audit_signature": { "proof": { "cryptosuite": "eddsa-jcs-2022", "verificationMethod": "did:example:analyst-a#key-1" } } }, { "duty_id": "monitor_ongoing_performance", "role": "approver", "record_type": "approval", "identity": { "id": "did:example:agent-1", "actor_type": "agent" }, "audit_signature": { "proof": { "cryptosuite": "eddsa-jcs-2022", "verificationMethod": "did:example:agent-1#key-1" } } } ] }, "output_payload": { "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", "shipped_duty_count": 7, "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" }, "position_ref": "POS-SYNTH-1", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2025-Q3", "start_date": "2025-07-01", "end_date": "2025-09-30", "bounds_present": true, "order_valid": true }, "duty_count": 7, "performed_count": 1, "duty_results": [ { "duty_id": "verify_credit_granting_standards", "position": 1, "duty_class": "verification_before_holding", "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The originator credit policy, and the investor record of the comparison made against its non-securitised book.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_credit_granting_standards", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_risk_retention", "position": 2, "duty_class": "verification_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The retention statement in the transaction documents, the retention holder identity, and the retention form relied on.", "performed_asserted": true, "evidence": [ { "evidence_ref": "EV-RET-1", "evidence_type": "transaction_document", "description": "Retention statement in the transaction documents naming the retention holder and the form relied on.", "dated": "2025-07-05", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "accountability_trail": { "duty_id": "verify_risk_retention", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 2, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:analyst-a" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." }, "approver": { "role": "approver", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:officer-b" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." } }, "record_count": 2, "status": "satisfied" }, "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.", "decided_by": "The investor function that performed the retention verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_article_7_disclosure", "position": 3, "duty_class": "verification_before_holding", "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "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.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_article_7_disclosure", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that obtained the information. This tool does not decide it.", "performed_note": null }, { "duty_id": "assess_risk_characteristics", "position": 4, "duty_class": "assessment_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written pre-investment assessment, and the source data and structural analysis it rests on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "assess_risk_characteristics", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that carried out the assessment. This tool does not decide it.", "performed_note": null }, { "duty_id": "monitor_ongoing_performance", "position": 5, "duty_class": "ongoing_monitoring", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written monitoring procedure, and the monitoring output for this period, including any waterfall recomputation performed on the period investor report.", "performed_asserted": true, "evidence": [ { "evidence_ref": "EV-MON-1", "evidence_type": "recomputation", "description": "Waterfall recomputation for the period, produced by art-509 from the period investor report and the priority ladder.", "dated": "2025-09-30", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "accountability_trail": { "duty_id": "monitor_ongoing_performance", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 1, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:analyst-a" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." }, "approver": { "role": "approver", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 2, "status": "hold" }, "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.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it.", "performed_note": null }, { "duty_id": "perform_stress_tests", "position": 6, "duty_class": "ongoing_monitoring", "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The stress test run for this period, its assumptions, and the record of who ran it.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": { "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.", "resolving_input": "The risk committee proportionality determination recorded for this position.", "decided_by": "The investor risk committee.", "named_completely": true }, "accountability_trail": { "duty_id": "perform_stress_tests", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor risk function that owns the stress testing. This tool does not decide it.", "performed_note": null }, { "duty_id": "report_internally", "position": 7, "duty_class": "ongoing_monitoring", "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The internal report covering this position and period, and the record of it reaching the management body.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "report_internally", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it.", "performed_note": null } ], "outstanding_duties": [ { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor investment or credit function that performed the verification. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that obtained the information. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(3)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that carried out the assessment. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)", "status": "evidence_unsigned", "what_is_missing": "The duty names evidence but no conformant signed record satisfies both required roles.", "decided_by": "The investor function that operates the monitoring procedure. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it." } ], "judgment_duties": [ { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "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.", "resolving_input": "The risk committee proportionality determination recorded for this position.", "decided_by": "The investor risk committee." } ], "agent_parity_findings": [ { "code": "ART5_AGENT_WITHOUT_HUMAN_ROLE_MANDATE", "duty_id": "monitor_ongoing_performance", "role": "approver", "identity_id": "did:example:agent-1", "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." } ], "override_record_count": 0, "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.", "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.", "rejected_citations": [], "citations": { "art5_1_a_credit_granting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_c_risk_retention": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_e_disclosure": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_3_risk_assessment": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_ongoing_monitoring": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_b_stress_testing": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_d_internal_reporting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art7_investor_report": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 7(1)(e)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" } }, "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." ], "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.", "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.", "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." }, "golden_hash": "8f3986b5d43645b85331349b2080665d1454e8c5f1332619a50c95cdfd9ac25d" }, { "name": "bare-year-citation-rejected", "description": "A caller supplies a citation whose in_force_from is a bare four-digit year. It is rejected and named in rejected_citations, and the shipped pinned citation stands in its place rather than the duty carrying an unpinned provision.", "policy_parameters": { "position_ref": "POS-SYNTH-2", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2025-Q4", "start_date": "2025-10-01", "end_date": "2025-12-31" }, "duty_declarations": [ { "duty_id": "verify_article_7_disclosure", "performed": true, "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021" }, "evidence": [ { "evidence_ref": "EV-DISC-1", "evidence_type": "record", "description": "Record of the period investor report having been obtained from the reporting entity.", "dated": "2025-11-04" } ] } ], "accountability_records": [ { "duty_id": "verify_article_7_disclosure", "role": "performer", "record_type": "approval", "identity": { "id": "did:example:analyst-a", "actor_type": "human" }, "audit_signature": { "proof": { "cryptosuite": "eddsa-jcs-2022", "verificationMethod": "did:example:analyst-a#key-1" } } }, { "duty_id": "verify_article_7_disclosure", "role": "approver", "record_type": "approval", "identity": { "id": "did:example:officer-b", "actor_type": "human" }, "audit_signature": { "proof": { "cryptosuite": "eddsa-jcs-2022", "verificationMethod": "did:example:officer-b#key-1" } } } ] }, "output_payload": { "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", "shipped_duty_count": 7, "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" }, "position_ref": "POS-SYNTH-2", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2025-Q4", "start_date": "2025-10-01", "end_date": "2025-12-31", "bounds_present": true, "order_valid": true }, "duty_count": 7, "performed_count": 1, "duty_results": [ { "duty_id": "verify_credit_granting_standards", "position": 1, "duty_class": "verification_before_holding", "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The originator credit policy, and the investor record of the comparison made against its non-securitised book.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_credit_granting_standards", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_risk_retention", "position": 2, "duty_class": "verification_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The retention statement in the transaction documents, the retention holder identity, and the retention form relied on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_risk_retention", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that performed the retention verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_article_7_disclosure", "position": 3, "duty_class": "verification_before_holding", "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "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.", "performed_asserted": true, "evidence": [ { "evidence_ref": "EV-DISC-1", "evidence_type": "record", "description": "Record of the period investor report having been obtained from the reporting entity.", "dated": "2025-11-04", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "accountability_trail": { "duty_id": "verify_article_7_disclosure", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 2, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:analyst-a" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." }, "approver": { "role": "approver", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:officer-b" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." } }, "record_count": 2, "status": "satisfied" }, "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.", "decided_by": "The investor function that obtained the information. This tool does not decide it.", "performed_note": null }, { "duty_id": "assess_risk_characteristics", "position": 4, "duty_class": "assessment_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written pre-investment assessment, and the source data and structural analysis it rests on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "assess_risk_characteristics", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "monitor_ongoing_performance", "position": 5, "duty_class": "ongoing_monitoring", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written monitoring procedure, and the monitoring output for this period, including any waterfall recomputation performed on the period investor report.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "monitor_ongoing_performance", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "perform_stress_tests", "position": 6, "duty_class": "ongoing_monitoring", "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The stress test run for this period, its assumptions, and the record of who ran it.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "perform_stress_tests", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor risk function that owns the stress testing. This tool does not decide it.", "performed_note": null }, { "duty_id": "report_internally", "position": 7, "duty_class": "ongoing_monitoring", "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The internal report covering this position and period, and the record of it reaching the management body.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "report_internally", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null } ], "outstanding_duties": [ { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it." }, { "duty_id": "verify_risk_retention", "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that performed the retention verification. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(3)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that carried out the assessment. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it." }, { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor risk function that owns the stress testing. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it." } ], "judgment_duties": [], "agent_parity_findings": [], "override_record_count": 0, "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.", "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.", "rejected_citations": [ { "where": "duty_declarations[verify_article_7_disclosure].citation", "reasons": [ "in_force_from is a bare four-digit year, which does not satisfy the pinned citation requirement; a full ISO date is required" ], "supplied_id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "supplied_in_force_from": "2021" } ], "citations": { "art5_1_a_credit_granting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_c_risk_retention": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_e_disclosure": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_3_risk_assessment": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_ongoing_monitoring": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_b_stress_testing": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_d_internal_reporting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art7_investor_report": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 7(1)(e)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" } }, "rationale": [ "Article 5 due-diligence evidence recorded for position POS-SYNTH-2 on deal SYNTH-2025-A, held by investor INV-SYNTH-1, for period 2025-Q4 running 2025-10-01 to 2025-12-31.", "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.", "6 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 supplied citation was rejected for not carrying a full ISO in_force_from date. A bare four-digit year does not pin a provision to a version, so the shipped pinned citation stands where one exists and the duty is carried as unusable where none does.", "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." ], "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.", "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.", "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." }, "golden_hash": "c8264ced10fa496d632fda9ec3cc607508a3c39810fea7e401861f3d0131d628" }, { "name": "superseded-citation-recorded-not-stripped", "description": "A caller supplies a valid pinned citation carrying a superseded_by record. 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A caller may declare additional duties carrying their own pinned citations.", "field_set_version": "1.0.0" }, "position_ref": "POS-SYNTH-3", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2025-Q4", "start_date": "2025-10-01", "end_date": "2025-12-31", "bounds_present": true, "order_valid": true }, "duty_count": 7, "performed_count": 1, "duty_results": [ { "duty_id": "verify_credit_granting_standards", "position": 1, "duty_class": "verification_before_holding", "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a) as originally enacted", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "superseded_by": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a) as substituted by Regulation (EU) 2021/557", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31" } }, "citation_source": "caller_supplied", "typical_evidence": "The originator credit policy, and the investor record of the comparison made against its non-securitised book.", "performed_asserted": true, "evidence": [ { "evidence_ref": "EV-CG-1", "evidence_type": "policy_document", "description": "Originator credit policy, and the comparison record against its non-securitised book.", "dated": "2025-10-15", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "accountability_trail": { "duty_id": "verify_credit_granting_standards", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 2, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:analyst-a" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." }, "approver": { "role": "approver", "approval_count": 1, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 1, "counted_identities": [ "did:example:officer-b" ], "status": "satisfied", "reason": "At least one signed record names a distinct identity in this role on this duty." } }, "record_count": 2, "status": "satisfied" }, "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. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_risk_retention", "position": 2, "duty_class": "verification_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The retention statement in the transaction documents, the retention holder identity, and the retention form relied on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_risk_retention", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_article_7_disclosure", "position": 3, "duty_class": "verification_before_holding", "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The reference to where the information was made available, and the investor record of having obtained it. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "assess_risk_characteristics", "position": 4, "duty_class": "assessment_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written pre-investment assessment, and the source data and structural analysis it rests on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "assess_risk_characteristics", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "perform_stress_tests", "position": 6, "duty_class": "ongoing_monitoring", "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The stress test run for this period, its assumptions, and the record of who ran it.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "perform_stress_tests", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null }, { "duty_id": "report_internally", "position": 7, "duty_class": "ongoing_monitoring", "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The internal report covering this position and period, and the record of it reaching the management body.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "report_internally", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. 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This tool does not decide it.", "performed_note": null } ], "outstanding_duties": [ { "duty_id": "verify_risk_retention", "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that performed the retention verification. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that obtained the information. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(3)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that carried out the assessment. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it." }, { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor risk function that owns the stress testing. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it." } ], "judgment_duties": [], "agent_parity_findings": [], "override_record_count": 0, "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.", "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.", "rejected_citations": [], "citations": { "art5_1_a_credit_granting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_c_risk_retention": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_e_disclosure": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_3_risk_assessment": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_ongoing_monitoring": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_b_stress_testing": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_d_internal_reporting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art7_investor_report": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 7(1)(e)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" } }, "rationale": [ "Article 5 due-diligence evidence recorded for position POS-SYNTH-3 on deal SYNTH-2025-A, held by investor INV-SYNTH-1, for period 2025-Q4 running 2025-10-01 to 2025-12-31.", "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.", "6 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.", "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." ], "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.", "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.", "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." }, "golden_hash": "0f5e801593afb8f94cc350c746841f0ecd14d77dd90e4a4e12a6eb68e7c4378b" }, { "name": "unsigned-evidence-holds", "description": "A duty is declared performed and names evidence, but no record carries a proof bound to the named identity. The duty is held as evidence_unsigned rather than passing on the assertion alone.", "policy_parameters": { "position_ref": "POS-SYNTH-4", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2026-Q1", "start_date": "2026-01-01", "end_date": "2026-03-31" }, "duty_declarations": [ { "duty_id": "assess_risk_characteristics", "performed": true, "evidence": [ { "evidence_ref": "EV-ASS-1", "evidence_type": "assessment", "description": "Written pre-investment assessment covering the position, the underlying exposures and the structural features.", "dated": "2026-01-20" } ] } ], "accountability_records": [ { "duty_id": "assess_risk_characteristics", "role": "performer", "record_type": "approval", "identity": { "id": "did:example:analyst-a", "actor_type": "human" } } ] }, "output_payload": { "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", "shipped_duty_count": 7, "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" }, "position_ref": "POS-SYNTH-4", "deal_ref": "SYNTH-2025-A", "investor_ref": "INV-SYNTH-1", "period": { "label": "2026-Q1", "start_date": "2026-01-01", "end_date": "2026-03-31", "bounds_present": true, "order_valid": true }, "duty_count": 7, "performed_count": 0, "duty_results": [ { "duty_id": "verify_credit_granting_standards", "position": 1, "duty_class": "verification_before_holding", "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The originator credit policy, and the investor record of the comparison made against its non-securitised book.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_credit_granting_standards", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_risk_retention", "position": 2, "duty_class": "verification_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The retention statement in the transaction documents, the retention holder identity, and the retention form relied on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_risk_retention", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that performed the retention verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_article_7_disclosure", "position": 3, "duty_class": "verification_before_holding", "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "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.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_article_7_disclosure", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that obtained the information. This tool does not decide it.", "performed_note": null }, { "duty_id": "assess_risk_characteristics", "position": 4, "duty_class": "assessment_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written pre-investment assessment, and the source data and structural analysis it rests on.", "performed_asserted": true, "evidence": [ { "evidence_ref": "EV-ASS-1", "evidence_type": "assessment", "description": "Written pre-investment assessment covering the position, the underlying exposures and the structural features.", "dated": "2026-01-20", "within_period": true } ], "evidence_count": 1, "judgment_required": null, "accountability_trail": { "duty_id": "assess_risk_characteristics", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 1, "unsigned_approval_count": 1, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "Sign-off records were supplied for this role but none carries a §16 proof bound to the named identity. An unsigned record is not conformant §27 evidence, so the role is held rather than passed." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 1, "status": "hold" }, "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.", "decided_by": "The investor function that carried out the assessment. This tool does not decide it.", "performed_note": null }, { "duty_id": "monitor_ongoing_performance", "position": 5, "duty_class": "ongoing_monitoring", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written monitoring procedure, and the monitoring output for this period, including any waterfall recomputation performed on the period investor report.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "monitor_ongoing_performance", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it.", "performed_note": null }, { "duty_id": "perform_stress_tests", "position": 6, "duty_class": "ongoing_monitoring", "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The stress test run for this period, its assumptions, and the record of who ran it.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "perform_stress_tests", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor risk function that owns the stress testing. This tool does not decide it.", "performed_note": null }, { "duty_id": "report_internally", "position": 7, "duty_class": "ongoing_monitoring", "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The internal report covering this position and period, and the record of it reaching the management body.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "report_internally", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it.", "performed_note": null } ], "outstanding_duties": [ { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it." }, { "duty_id": "verify_risk_retention", "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that performed the retention verification. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that obtained the information. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(3)", "status": "evidence_unsigned", "what_is_missing": "The duty names evidence but no conformant signed record satisfies both required roles.", "decided_by": "The investor function that carried out the assessment. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it." }, { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor risk function that owns the stress testing. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it." } ], "judgment_duties": [], "agent_parity_findings": [], "override_record_count": 0, "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.", "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.", "rejected_citations": [], "citations": { "art5_1_a_credit_granting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_c_risk_retention": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_e_disclosure": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_3_risk_assessment": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_ongoing_monitoring": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_b_stress_testing": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_d_internal_reporting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art7_investor_report": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 7(1)(e)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" } }, "rationale": [ "Article 5 due-diligence evidence recorded for position POS-SYNTH-4 on deal SYNTH-2025-A, held by investor INV-SYNTH-1, for period 2026-Q1 running 2026-01-01 to 2026-03-31.", "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.", "0 of the 7 duties carry a performance declaration, named evidence, and a signed record naming both a performer and an approver by distinct identity.", "7 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.", "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." ], "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.", "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.", "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." }, "golden_hash": "a3d9d98cd3104210bb3dd8077b3b248294f39f6748b59b0ed399e83993d50b2e" }, { "name": "empty-declaration-set-finite-gate", "description": "Finite gate. Nothing declared at all resolves to a defined result: every shipped duty is outstanding, the period is reported as unbounded, and no status is undefined.", "policy_parameters": {}, "output_payload": { "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", "shipped_duty_count": 7, "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" }, "position_ref": "UNSTATED", "deal_ref": "UNSTATED", "investor_ref": "UNSTATED", "period": { "label": "UNSTATED", "start_date": null, "end_date": null, "bounds_present": false, "order_valid": true }, "duty_count": 7, "performed_count": 0, "duty_results": [ { "duty_id": "verify_credit_granting_standards", "position": 1, "duty_class": "verification_before_holding", "label": "Verify that the originator or original lender grants credits on the same sound and well-defined criteria it applies to non-securitised exposures.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The originator credit policy, and the investor record of the comparison made against its non-securitised book.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_credit_granting_standards", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_risk_retention", "position": 2, "duty_class": "verification_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The retention statement in the transaction documents, the retention holder identity, and the retention form relied on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_risk_retention", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that performed the retention verification. This tool does not decide it.", "performed_note": null }, { "duty_id": "verify_article_7_disclosure", "position": 3, "duty_class": "verification_before_holding", "label": "Verify that the originator, sponsor or securitisation special purpose entity has made available the information required by Article 7.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "citation_source": "shipped_pin", "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.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "verify_article_7_disclosure", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that obtained the information. This tool does not decide it.", "performed_note": null }, { "duty_id": "assess_risk_characteristics", "position": 4, "duty_class": "assessment_before_holding", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written pre-investment assessment, and the source data and structural analysis it rests on.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "assess_risk_characteristics", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that carried out the assessment. This tool does not decide it.", "performed_note": null }, { "duty_id": "monitor_ongoing_performance", "position": 5, "duty_class": "ongoing_monitoring", "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.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The written monitoring procedure, and the monitoring output for this period, including any waterfall recomputation performed on the period investor report.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "monitor_ongoing_performance", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it.", "performed_note": null }, { "duty_id": "perform_stress_tests", "position": 6, "duty_class": "ongoing_monitoring", "label": "Perform regular stress tests on the cash flows and collateral values supporting the underlying exposures, proportionate to the risk of the position.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The stress test run for this period, its assumptions, and the record of who ran it.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "perform_stress_tests", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor risk function that owns the stress testing. This tool does not decide it.", "performed_note": null }, { "duty_id": "report_internally", "position": 7, "duty_class": "ongoing_monitoring", "label": "Ensure internal reporting to the management body so that material risks arising from the position are known and are managed.", "citation": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "citation_source": "shipped_pin", "typical_evidence": "The internal report covering this position and period, and the record of it reaching the management body.", "performed_asserted": false, "evidence": [], "evidence_count": 0, "judgment_required": null, "accountability_trail": { "duty_id": "report_internally", "required_roles": [ "performer", "approver" ], "roles_satisfied_count": 0, "roles_required_count": 2, "by_role": { "performer": { "role": "performer", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." }, "approver": { "role": "approver", "approval_count": 0, "unsigned_approval_count": 0, "rejection_count": 0, "counted_identity_count": 0, "counted_identities": [], "status": "hold", "reason": "No qualifying signed record for this role on this duty. Absent evidence holds; it is never a fall-through pass." } }, "record_count": 0, "status": "hold" }, "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.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it.", "performed_note": null } ], "outstanding_duties": [ { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor investment or credit function that performed the verification. This tool does not decide it." }, { "duty_id": "verify_risk_retention", "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that performed the retention verification. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that obtained the information. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(3)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that carried out the assessment. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor function that operates the monitoring procedure. This tool does not decide it." }, { "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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor risk function that owns the stress testing. 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.", "citation_id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "status": "outstanding", "what_is_missing": "The duty is not declared performed for this position and period.", "decided_by": "The investor management body, on the report placed before it. This tool does not decide it." } ], "judgment_duties": [], "agent_parity_findings": [], "override_record_count": 0, "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.", "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.", "rejected_citations": [], "citations": { "art5_1_a_credit_granting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(a)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_c_risk_retention": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(c)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_1_e_disclosure": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(1)(e)", "in_force_from": "2021-04-09", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2021/557/oj" }, "art5_3_risk_assessment": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(3)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_ongoing_monitoring": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_b_stress_testing": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(b)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art5_4_d_internal_reporting": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 5(4)(d)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" }, "art7_investor_report": { "scheme": "eu-regulation", "id": "Regulation (EU) 2017/2402 Article 7(1)(e)", "in_force_from": "2019-01-01", "mapped_by": "AINumbers SECZ-K-1", "mapped_at": "2026-07-31", "uri": "https://eur-lex.europa.eu/eli/reg/2017/2402/oj" } }, "rationale": [ "Article 5 due-diligence evidence recorded for position UNSTATED on deal UNSTATED, held by investor UNSTATED, for period UNSTATED.", "The period is not fully bounded, so no piece of evidence can be placed inside or outside it. Each evidence reference is carried with within_period left null rather than guessed.", "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.", "0 of the 7 duties carry a performance declaration, named evidence, and a signed record naming both a performer and an approver by distinct identity.", "7 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.", "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." ], "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.", "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.", "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." }, "golden_hash": "0d1918fd799a7113ed4e77683765b2a55db8f77981ddb11b2c78df7daa1e63f5" } ] }