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

Which FCA Dear CEO letters remain in force after Consumer Duty implementation

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020

What the RLB Specialist Panel found

10. Which FCA Dear CEO letters remain in force after Consumer Duty implementation

Question (paraphrased to protect IP): Which FCA Dear CEO letters remain in force after Consumer Duty implementation? Has the FCA withdrawn any letters that previously set consumer protection expectations?
Source regulation: Consumer Duty (PS22/9 + PRIN 2A), Financial Conduct Authority (Regulator portal: https://www.fca.org.uk)
What AI assistants typically say: AI tools again gave two types of wrong answer on this question. One tool described the withdrawal programme as two separate tranches — approximately 90 Dear CEO letters retired in April 2025, and more than 100 multi-firm and thematic reports retired in August 2025 — with no reference to the relevant FCA publication. Another tool stated it could not identify a verified count or a complete current list from available sources.
What the regulator actually says: Under FS25/2 (March 2025), the FCA reviewed all Dear CEO letters pre-dating its 2022–25 strategy and withdrew more than 90 such letters, which are no longer live supervisory expectations.
Why the AI went wrong: One AI tool fabricated a two-tranche withdrawal timeline with dates that do not correspond to any FCA publication. The other was unaware of FS25/2 entirely and gave no answer. Both failures leave a lawyer unable to advise accurately on which supervisory expectations a regulated firm must currently observe, a gap that carries direct consequences for any client whose compliance programme is built around a Dear CEO letter that may no longer be live.
Cited source(s):
https://www.fca.org.uk/news/news-stories/fca-simplifies-supervisory-letters — Pretextual
https://www.fca.org.uk/publication/correspondence/consumer-duty-letter-retail... — Pretextual
https://www.fca.org.uk/publication/correspondence/dear-ceo-letter-implementin... — Pretextual
https://www.fca.org.uk/news/news-stories/next-steps-consumer-duty-rule-review — Pretextual
https://www.cliffordchance.com/insights/resources/blogs/regulatory-investigat... — Fabricated

Impact for this audience

A lawyer advising on which supervisory expectations a regulated firm must currently observe — for example, in a compliance audit, an onboarding engagement, or a response to an FCA information request — needs accurate information about the current status of Dear CEO letters. AI tools tested here either fabricated a two-tranche withdrawal timeline with invented dates, or could not answer the question at all. A firm that continues to treat a withdrawn Dear CEO letter as a live obligation wastes compliance resource; a firm that treats a live letter as withdrawn faces supervisory risk. The FCA can use Dear CEO letters as the basis for supervisory engagement and enforcement action, and advice about their current status has direct implications for how a regulated firm manages its ongoing relationship with the regulator.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q020-Opus47 Claude Opus 4.7 (web search on)
RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q020-Sonnet46 Claude Sonnet 4.6 (web search on)

This finding also affects

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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). "Which FCA Dear CEO letters remain in force after Consumer Duty implementation — Practitioners — Lawyers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). Which FCA Dear CEO letters remain in force after Consumer Duty implementation [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Which FCA Dear CEO letters remain in force after Consumer Duty implementation [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Which FCA Dear CEO letters remain in force after Consumer Duty implementation},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020},
  url       = {https://reglegbrief.com/audiences/practitioners/GB/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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