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

Which pre-Consumer Duty Dear CEO letters remain live supervisory expectations?

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

What the RLB Specialist Panel found

10. Which pre-Consumer Duty Dear CEO letters remain live supervisory expectations?

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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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: Multiple AI tools gave divergent incorrect responses. One stated that around 90+ Dear CEO and portfolio letters were retired in April 2025 and a further 100+ multi-firm and thematic reports were retired in August 2025 — framing these as two separate events. The other stated that no publicly available consolidated list exists and that it could not provide a verified count or complete current list.
What the regulator actually says: From FS25/2 (March 2025): the FCA reviewed all Dear CEO letters pre-dating the 2022-25 strategy and withdrew more than 90 such letters. These are no longer live supervisory expectations.
Why the AI went wrong: One AI tool fabricated two distinct retirement events with incorrect dates (April 2025 and August 2025) and failed to identify FS25/2 as the governing document — the actual event occurred in March 2025 and covered both letters and reports in a single published action. The other AI claimed the information was simply unavailable, despite FS25/2 providing precisely the figures requested. Both responses leave a practitioner unable to distinguish which historic supervisory communications continue to carry regulatory weight.
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

Knowing which pre-Consumer Duty Dear CEO letters remain live is not an academic question for Financial Advisers — it directly affects what their clients must do to demonstrate compliance with historic supervisory expectations. An AI tool that fabricates incorrect retirement dates or simply says it cannot answer leaves the adviser unable to give their client accurate guidance on whether a specific letter continues to carry regulatory weight. A firm that treats a withdrawn letter as still live may resource a compliance programme around redundant expectations; a firm that treats a still-live letter as withdrawn may be exposed in the next FCA review. FS25/2 is the document that resolves this — and both AI tools failed to identify or accurately represent it.

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

← Previous finding Finding 9. Consumer Duty scope exclusions — reinsurance, group insurance, and large commercial risks

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 pre-Consumer Duty Dear CEO letters remain live supervisory expectations? — Practitioners — Financial Advisers." 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/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). Which pre-Consumer Duty Dear CEO letters remain live supervisory expectations? [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Which pre-Consumer Duty Dear CEO letters remain live supervisory expectations? [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Which pre-Consumer Duty Dear CEO letters remain live supervisory expectations?},
  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/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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