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

Dear CEO letters remaining in force after Consumer Duty implementation

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

What the RLB Specialist Panel found

9. Dear CEO letters remaining 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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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: Multiple AI tools gave divergent but both incorrect responses. One fabricated a two-event withdrawal programme — approximately 90+ Dear CEO and portfolio letters retired in April 2025, and 100+ multi-firm and thematic reports retired in August 2025 — without citing the relevant FCA document. The other stated it could not identify a verified count or a complete current list, describing no definitive public record of which letters had been formally withdrawn.
What the regulator actually says: From FS25/2 (March 2025), the FCA reviewed all Dear CEO letters pre-dating its 2022–25 strategy and withdrew more than 90 such letters. These are no longer live supervisory expectations.
Why the AI went wrong: Neither AI tool identified FS25/2 as the relevant document. One filled that gap with fabricated dates and figures split across two imagined events; the other acknowledged it could not answer but was unaware that the FCA had published specific figures in a named document. A Compliance team using either response to determine which supervisory letters still apply would be working from a materially incorrect picture of the current supervisory landscape.
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 Compliance team that holds fabricated or absent information about which Dear CEO letters remain in force may maintain policies and procedures that reference withdrawn letters as live supervisory expectations, creating a compliance framework anchored to requirements that no longer exist in that form. Equally, where the firm is uncertain which letters remain in force, it may apply an over-broad set of supervisory expectations without a clear basis. The FCA's FS25/2 statement is the definitive reference for this question; a firm that cannot demonstrate awareness of it may face questions in supervisory engagement about how it tracks changes to the FCA's supervisory framework.

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 8. Changes between CP21/36 consultation and PS22/9 final rules

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). "Dear CEO letters remaining in force after Consumer Duty implementation — Financial Advisory × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020. 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-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). Dear CEO letters remaining 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/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Dear CEO letters remaining 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/sectors/gb/financial_advisory/compliance/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     = {Dear CEO letters remaining 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/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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