General Insurance × Compliance — United Kingdom · published 2026-05-26 · methodology v2.1

Withdrawal of pre-Consumer Duty Dear CEO letters: count and timing

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

What the RLB Specialist Panel found

2. Withdrawal of pre-Consumer Duty Dear CEO letters: count 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Question (paraphrased to protect IP): Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?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: Multiple AI tools gave similar incorrect responses. One invented two separate withdrawal events — attributing around 90 Dear CEO letters to April 2025 and a further tranche of multi-firm and thematic reports to August 2025 — while omitting the FCA's own published source entirely. A second AI tool stated it could not identify a definitive public count of withdrawn letters and declined to provide one.
What the regulator actually says: FS25/2 (March 2025): FCA removed more than 90 pre-Consumer Duty Dear CEO letters and cleared over 100 old multi-firm reports.
Why the AI went wrong: One AI tool fabricated both the dates and the structure of the withdrawal programme, splitting a single documented FCA action into two fictional events. The other appeared unaware that FS25/2 exists as a specific published document and defaulted to disclaiming knowledge rather than locating the answer. Both responses leave the reader without accurate supervisory intelligence.
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 General Insurance Compliance team relying on AI-generated answers about the FCA's supervisory letter landscape will either carry forward fabricated withdrawal dates into regulatory briefings and board reporting, or will report to leadership that no reliable information is available — both of which undermine the firm's ability to maintain an accurate map of live supervisory expectations. Boards and senior managers making decisions about Consumer Duty programme scope and resource allocation on the basis of incorrect or incomplete supervisory intelligence face regulatory risk if their programme fails to reflect obligations that remain in force, or invests resource in monitoring letters that have already been withdrawn.

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 1. Harm-avoidance standard: the "reasonably believes" qualifier Next finding → Finding 3. Consumer Duty scope: reinsurance, group insurance, and large-risk commercial contracts

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). "Withdrawal of pre-Consumer Duty Dear CEO letters: count and timing — General Insurance × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/sectors/gb/general_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

APA 7th edition

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

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Withdrawal of pre-Consumer Duty Dear CEO letters: count and timing [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/general_insurance/compliance/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     = {Withdrawal of pre-Consumer Duty Dear CEO letters: count 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/sectors/gb/general_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/}
}

← Back to case study summary Case study detail →

About Citation IDs →