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Practitioners — Lawyers · published 2026-05-26 · methodology v2.1

Quantifying non-monetary benefits in Consumer Duty fair value assessments

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008
What the RLB Specialist Panel found

5. Quantifying non-monetary benefits in Consumer Duty fair value assessments

  • Question (paraphrased to protect IP): Does the Consumer Duty require firms to quantify non-monetary benefits as part of a fair value assessment? What methodology does the FCA expect?
  • Source regulation: Consumer Duty (PS22/9 + PRIN 2A), Financial Conduct Authority (Regulator portal: https://www.fca.org.uk)
  • What AI assistants typically say: The AI described quantification of non-monetary benefits as "encouraged where feasible," with qualitative assessment acceptable only where quantification is impractical and the reasoning is robust. This framing presents quantification as a positive expectation — something the FCA wants firms to do when they can.
  • What the regulator actually says: The FCA does not expect firms to quantify non-monetary costs and benefits as part of its fair value assessment process, but firms should undertake some form of qualitative assessment.
  • Why the AI went wrong: The AI converted the FCA's explicitly permissive position — the regulator does not expect quantification — into an affirmative expectation that quantification should be attempted where feasible. This overstates the regulatory burden and misrepresents the FCA's published standard, which requires qualitative assessment but deliberately does not require quantification.
  • Cited source(s):
  • https://handbook.fca.org.uk/handbook/PRIN/2A/4.html — Pretextual
  • https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf — Pretextual
Impact for this audience

A lawyer advising on a regulated firm's Consumer Duty fair value framework needs to state accurately what the FCA expects on quantification of non-monetary benefits. AI tools tested here converted the FCA's permissive position — it does not expect quantification — into an affirmative expectation that quantification is encouraged where feasible. A firm whose fair value policy is drafted against this AI-derived formulation may invest significant compliance resource in building quantification models the FCA has not required. A lawyer's advice note reflecting this position would misstate the FCA's published standard and, if scrutinised during an FCA review of the firm's fair value process, could be demonstrated to be factually incorrect.

References — raw findings (per AI model)
This finding also affects
← Previous finding Finding 4. Consumer testing of communications — mandatory rule or non-binding guidance? Next finding → Finding 6. FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing
Cite this finding

Each finding has a stable Citation ID (RLB-F-… for aggregated case-study findings, RLB-H-… for raw per-model hallucinations) — like a DOI, the ID always resolves to the canonical finding even if URLs change.

Plain text 
RegLeg Specialist Panel (2026). "Quantifying non-monetary benefits in Consumer Duty fair value assessments — Practitioners — Lawyers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/
APA 7th edition 
RegLeg Specialist Panel. (2026). Quantifying non-monetary benefits in Consumer Duty fair value assessments [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/
Bluebook / OSCOLA (US + UK legal) 
RegLeg Specialist Panel, Quantifying non-monetary benefits in Consumer Duty fair value assessments [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/.
BibTeX 
@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q008,
  author    = {RegLeg Specialist Panel},
  title     = {Quantifying non-monetary benefits in Consumer Duty fair value assessments},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008},
  url       = {https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/}
}
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