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

Live supervisory expectations: which Dear CEO letters remain in force

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

What the RLB Specialist Panel found

4. Live supervisory expectations: which Dear CEO letters remain in force

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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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 similar incorrect responses. One described the withdrawal programme as two separate events — around 90 Dear CEO and portfolio letters retired in April 2025 and over 100 multi-firm and thematic reports retired in August 2025 — without referencing the FCA's published source. A second AI tool stated explicitly that no publicly available consolidated list identifies exactly which pre-Consumer Duty letters have been formally withdrawn and that it could not provide a verified count.
What the regulator actually says: From FS25/2 (March 2025): FCA reviewed all Dear CEO letters pre-dating the 2022–25 strategy and withdrew 90+ such letters. These are no longer live supervisory expectations.
Why the AI went wrong: One AI tool fabricated the dates and fragmented a single documented event into two fictional ones, while also citing a third-party law firm blog as a source — a Fabricated citation — rather than the FCA's own publication. The second tool disclaimed all knowledge of the withdrawal programme despite FS25/2 being a publicly accessible FCA document. Both failures leave a Compliance team without reliable intelligence on which supervisory letters still carry regulatory weight.
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

If a General Insurance firm's regulatory intelligence function or Compliance team uses AI-generated output to determine which Dear CEO letters remain live, it risks either treating withdrawn letters as still carrying supervisory weight — misallocating monitoring and reporting resource — or, where the AI disclaims knowledge entirely, leaving the firm without a reliable picture of current FCA expectations at all. For firms managing Consumer Duty implementation programmes, an inaccurate understanding of which legacy supervisory letters have been retired can distort gap analyses, board risk assessments, and the firm's overall Consumer Duty governance narrative in ways that become visible and costly to correct during FCA engagement.

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 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). "Live supervisory expectations: which Dear CEO letters remain in force — General Insurance × 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/general_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). Live supervisory expectations: which Dear CEO letters remain in force [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/general_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Live supervisory expectations: which Dear CEO letters remain in force [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], 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-v1-020/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Live supervisory expectations: which Dear CEO letters remain in force},
  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/general_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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