Financial Advisory × Compliance — United Kingdom · Last updated 26 May 2026 · methodology v2.1 · Hallucination Register

Dear CEO letters remaining in force after Consumer Duty implementation

RLB Citation ID: 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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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a verified count or a complete current list, describing no definitive public record of which letters had been formally withdrawn.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 Compliance Teams in Financial Advisory Sector in United Kingdom working with the AI Hallucinations Affecting Compliance at Financial Advisory Firms in the United Kingdom

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 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.

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020

Plain text Download

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 Download

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) Download

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 Download

@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/}
}

← Back to case study summary Case study detail →

About Citation IDs →

Every finding on this page compares an AI subject's account of the rule against the regulator's verbatim text from the regulator's own portal. Both are linked. Each delta, its root causes, and impact analysis are documented and published with immutable Citation IDs.