Insurance Intermediaries × Compliance — United Kingdom · published 2026-05-28 · methodology v2.1

FCA withdrawal of pre-Consumer Duty Dear CEO letters under FS25/2

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

What the RLB Specialist Panel found

3. FCA withdrawal of pre-Consumer Duty Dear CEO letters under FS25/2

Question (paraphrased to protect IP): Which pre-Consumer Duty Dear CEO letters remain in force, and has the FCA withdrawn letters that previously set consumer protection expectations?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: AI tools stated that in April 2025 the FCA retired around 90 or more Dear CEO and portfolio letters, and in August 2025 retired 100 or more multi-firm and thematic reports, marking them as historical.
What the regulator actually says: From FS25/2 (March 2025): the 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: The source attributes both the Dear CEO letter withdrawals and the multi-firm report clearances to the same FCA publication, FS25/2, issued in March 2025. AI tools misassigned the letter withdrawals to April 2025, invented a separate August 2025 tranche for multi-firm reports, and omitted the FS25/2 reference entirely — producing a timeline that cannot be verified against any real FCA publication.
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

Impact for this audience

A Compliance team that relies on the AI's timeline — April and August 2025 tranches, with no FS25/2 reference — cannot verify what the FCA actually withdrew or when, because those dates and that tranche structure do not correspond to any real FCA publication. The practical consequence is that the team cannot produce a reliable audit trail of which Dear CEO letters remain live supervisory expectations and which have been withdrawn, leaving the firm's customer communications monitoring programme potentially anchored to obsolete expectations or missing current ones. If the FCA were to review the firm's Consumer Duty implementation and found that it was calibrated against a letter the regulator had withdrawn, or that it was unaware of a letter that remained live, the Compliance function would need to explain the gap — at the cost of remediation time, external advice, and potential supervisory scrutiny.

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 2. Consumer Duty scope exclusions for reinsurance and group insurance distribution

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). "FCA withdrawal of pre-Consumer Duty Dear CEO letters under FS25/2 — Insurance Intermediaries × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020. RegLegBrief AI Hallucination Research, published 2026-05-28. https://reglegbrief.com/audiences/sectors/gb/insurance_intermediaries/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). FCA withdrawal of pre-Consumer Duty Dear CEO letters under FS25/2 [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/insurance_intermediaries/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, FCA withdrawal of pre-Consumer Duty Dear CEO letters under FS25/2 [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], RegLegBrief AI Hallucination Research (May 28, 2026), https://reglegbrief.com/audiences/sectors/gb/insurance_intermediaries/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     = {FCA withdrawal of pre-Consumer Duty Dear CEO letters under FS25/2},
  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/insurance_intermediaries/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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