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

FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013

What the RLB Specialist Panel found

6. FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing

Question (paraphrased to protect IP): Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?
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 gave two distinct types of wrong answer. One tool described the withdrawal programme as two separate events — around 90 Dear CEO letters retired in April 2025 and more than 100 multi-firm and thematic reports retired in August 2025 — and made no reference to the relevant FCA publication. Another tool explicitly stated it could not verify a count or identify a definitive list from its available sources.
What the regulator actually says: In FS25/2 (published March 2025), the FCA removed more than 90 pre-Consumer Duty Dear CEO letters and cleared over 100 old multi-firm reports. Both actions were part of the same published review.
Why the AI went wrong: One AI tool invented a two-tranche timeline with fabricated dates — neither April 2025 nor August 2025 correspond to the FCA's published record — and omitted the source document entirely. The other was unaware of FS25/2 and accordingly could not provide the information the question asked for. Both failures leave the practitioner without accurate knowledge of the FCA's current supervisory expectations.
Cited source(s):
https://www.fca.org.uk/news/news-stories/fca-simplifies-supervisory-letters — Pretextual
https://www.fca.org.uk/news/news-stories/next-steps-consumer-duty-rule-review — Pretextual

Impact for this audience

A lawyer advising a regulated firm on which supervisory expectations remain live after Consumer Duty implementation needs to know both the scale and the source of the FCA's withdrawal programme. AI tools tested here either fabricated a two-event timeline with incorrect dates — making the programme appear to consist of a separate letters tranche and reports tranche — or admitted they could not provide a count. The FCA's Dear CEO letters have historically been used as a basis for supervisory action, and advice about which letters remain live has direct implications for a firm's compliance programme and its ongoing relationship with the FCA. Advice based on fabricated or unavailable information leaves both the lawyer and client without an accurate picture of current regulatory expectations.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q013-Opus47 Claude Opus 4.7 (web search on)
RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q013-Sonnet46 Claude Sonnet 4.6 (web search on)

This finding also affects

← Previous finding Finding 5. Quantifying non-monetary benefits in Consumer Duty fair value assessments Next finding → Finding 7. FCA public commentary on first-year Consumer Duty compliance

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). "FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing — Practitioners — Lawyers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/practitioners/gb/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

APA 7th edition

RegLeg Specialist Panel. (2026). FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/practitioners/gb/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/practitioners/gb/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q013,
  author    = {RegLeg Specialist Panel},
  title     = {FCA withdrawal of pre-Consumer Duty Dear CEO letters — scale and timing},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013},
  url       = {https://reglegbrief.com/audiences/practitioners/gb/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/}
}

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