Of course it matters! AI doesn't automatically absolve you from your legal responsibilities...

I'd bet there's a person somewhere that receives money in exchange for sharing the AI's analysis, which would fall squarely into the second half of the definition:

[any person] who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities...

The person who made the tool is culpable. Same way if a lawyer hires an intern that preps legal documents is responsible.

However, governments in thw US love to whitewash liability so this is just academic.