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Financial Advisory × Compliance — United Kingdom · published 2026-05-26 · methodology v2.1

Fair value assessment — quantification of non-monetary benefits

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

5. Fair value assessment — quantification of non-monetary benefits

  • 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 characterised quantification of non-monetary items as "encouraged where feasible" — implying a positive FCA expectation — while stating qualitative assessment was only acceptable where quantification was impractical. Another stated that the FCA expects firms to "go beyond qualitative description" and provide substantiated comparisons, directly inverting the regulatory position.
  • What the regulator actually says: The FCA does not expect firms to quantify non-monetary costs and benefits as part of the fair value assessment process, but firms should undertake some form of qualitative assessment.
  • Why the AI went wrong: The FCA's actual position is that quantification is not expected — qualitative assessment is what the regulator requires. Both AI responses inverted this stance, either by framing quantification as encouraged or by suggesting qualitative assessment alone is insufficient. A Compliance team using either answer to design its fair value assessment methodology would be building unnecessary and inaccurate obligations into its process.
  • 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

A fair value assessment methodology designed around the AI's characterisation of the FCA's expectations — treating quantification of non-monetary benefits as encouraged or required — would impose unnecessary analytical obligations on the firm and potentially generate internal pressure to produce quantified figures for items the FCA accepts can be handled qualitatively. Where the firm then presents its fair value assessment to the FCA in a supervisory context, a methodology misaligned with the FCA's stated expectations may invite questions about whether the firm's approach is proportionate or whether the qualitative assessment it did produce was robust. Conversely, a firm that builds its methodology on the AI's inverted account may feel it has satisfied the FCA's requirements when it has not addressed the qualitative assessment the FCA actually expects.

References — raw findings (per AI model)
This finding also affects
← Previous finding Finding 4. Consumer testing of communications — rule versus guidance Next finding → Finding 6. FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2
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). "Fair value assessment — quantification of non-monetary benefits — Financial Advisory × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/
APA 7th edition 
RegLeg Specialist Panel. (2026). Fair value assessment — quantification of non-monetary benefits [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/
Bluebook / OSCOLA (US + UK legal) 
RegLeg Specialist Panel, Fair value assessment — quantification of non-monetary benefits [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/financial_advisory/compliance/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     = {Fair value assessment — quantification of non-monetary benefits},
  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/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/}
}
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