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

Quantification of non-monetary benefits in fair value assessments

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

5. Quantification of non-monetary benefits in 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: Multiple AI tools gave similar incorrect responses. One stated that quantification of non-monetary benefits is "encouraged where feasible" but that qualitative assessment is acceptable where quantification is impractical. A second stated that firms must "go beyond qualitative description" and provide substantiated comparisons.
  • 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: Both AI responses inverted the FCA's actual position. The FCA guidance is explicit that quantification is not expected — qualitative assessment is what the regulator requires. One AI tool converted this permissive non-expectation into positive encouragement; the other directly contradicted it by saying firms must move beyond qualitative description. A practitioner who follows either version would design a more burdensome internal process than the FCA actually requires, and may misrepresent their obligations in a regulatory submission.
  • 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
  • https://www.fca.org.uk/publications/good-and-poor-practice/consumer-duty-find... — Pretextual
Impact for this audience

Fair value assessments sit at the centre of Consumer Duty compliance for product manufacturers and distributors, and Financial Advisers are regularly asked to assist clients in designing or reviewing these assessments. An adviser who acts on the AI's inverted position — treating quantification of non-monetary benefits as encouraged or required — will design a more burdensome process than the FCA expects and may misrepresent the standard to their client. Worse, in a regulatory return or a response to an FCA data request, a firm that has built its fair value framework around a more demanding test than the regulator actually imposed is not better protected — it has simply misunderstood the framework it is trying to demonstrate compliance with.

References — raw findings (per AI model)
This finding also affects
← Previous finding Finding 4. Consumer testing of communications — mandatory rule or guidance recommendation? Next finding → Finding 6. FCA withdrawal of pre-Consumer Duty Dear CEO letters — volume 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). "Quantification of non-monetary benefits in fair value assessments — Practitioners — Financial Advisers." 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/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/
APA 7th edition 
RegLeg Specialist Panel. (2026). Quantification of non-monetary benefits in fair value assessments [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/
Bluebook / OSCOLA (US + UK legal) 
RegLeg Specialist Panel, Quantification of non-monetary benefits in 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/financial-advisers/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     = {Quantification of non-monetary benefits in 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/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/}
}
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