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CCAR-PLessons

CCAR-P · Governance, Safety & Risk Management

LLM failure modes, calculations, non-determinism, hallucination and the audit trail

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An expense-audit agent applies the policy well, but every now and then it adds up a report’s totals wrong and flags the wrong person. At another company, a lender plans to answer auditors by regenerating the explanations for its credit pre-screenings at temperature zero, “so they come out the same”. Both designs treat the model as something it isn’t.

What an LLM is not

An LLM is not a calculator, a database or a deterministic system. Each known failure mode has its control, and that control is almost never one more instruction in the prompt:

Failure mode What it looks like Control
Arithmetic and exact calculations totals, conversions or dates calculated wrong a calculation tool or code, and validating the result outside the model
Non-determinism the same input gives different outputs, even at temperature zero store what was produced; never reconstruct by regenerating
Hallucination invented data, quotes or policies, stated confidently grounding in documents, verifiable citations, permission to say “I don’t know”
Knowledge cutoff outdated information presented as current retrieve from current sources with their date
Drift in long contexts rules followed less in long conversations controls outside the model (layered guardrails lesson)
Poorly calibrated confidence sounds just as sure when right as when wrong combine stated confidence with verifiable signals: validations, matching sources, business rules

The division of labor is the central idea: the model does what it does well (interpreting, applying judgment, writing) and delegates what has to be exact. In the expense agent, the policy stays with the model and a tool calculates the totals, with a check in code before anyone is flagged.

The audit trail

If a regulator or a customer asks “why was this decided?”, the answer can’t depend on running the model again. Besides the output possibly varying, between the decision and the audit the prompt, the model and the external data all change. The audit trail stores, for each decision:

  • the inputs as they were used, including retrieved documents and third-party data consulted;
  • the prompt version, model ID and parameters;
  • the tool calls and their results;
  • the full output and what the reviewer did next, if there was one;
  • date and time, with an identifier that ties everything together.

That record is designed as one more requirement: retention under the applicable regulation, restricted access and handling of the personal data it contains. Pinning the prompt and the model forever doesn’t replace it; it only freezes the system without guaranteeing that regeneration will match.

The usual traps

  • Lowering the temperature to zero so “the sums always come out the same”: it makes the same mistake more consistently.
  • Asking the model to reason through each sum step by step or moving to a larger one: fewer mistakes, but still not exact.
  • Planning the audit around regenerating outputs, even at temperature zero or with top_k set to one.
  • Storing only the explanation text, without the inputs that produced it.
  • Using the model’s stated confidence as the only gate for deciding without review.

On the exam

If the scenario shows calculation errors while the rest of the judgment works, look for the option that delegates the calculation to a tool or code and validates outside the model. If someone wants to reconstruct past decisions by regenerating them, the answer is to persist inputs, versions and output as the record. Rule out any option that tries to make the model exact or deterministic through parameters.

Quick question

A practice exam question on this domain. It counts towards your progress.

A federal agency wants to pilot a Claude assistant that helps caseworkers summarise benefit applications. The agency's authorising official has stated that any system processing these records must run within a FedRAMP High authorised boundary, and the agency already runs its workloads in a government region of a major cloud provider.

The pilot would use real applications from two field offices. To start quickly, the project team proposes running the six-week pilot on the standard commercial API with a system prompt instructing the model not to store citizen data, and moving to a compliant setup later if the pilot succeeds.

What should the architect recommend for the pilot?

Practise this domain in a practice exam →