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

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

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

What the RLB Specialist Panel found

5. FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2

Question (paraphrased to protect IP): Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?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 different but equally unreliable responses. One fabricated a two-stage withdrawal programme — around 90 Dear CEO letters retired in April 2025, with a further tranche of multi-firm and thematic reports retired in August 2025 — inventing both dates and the two-event structure. The other stated it could not provide a verified count and that no definitive public list of withdrawn letters was available in its search results.
What the regulator actually says: Under FS25/2 (published March 2025), the FCA removed more than 90 pre-Consumer Duty Dear CEO letters and cleared over 100 old multi-firm reports. Both actions were part of a single published initiative, not two separate events.
Why the AI went wrong: One AI tool confabulated specific dates and a two-stage narrative that does not match the FCA's published account — a fabrication that could mislead a Compliance team about the current supervisory landscape. The other tool was simply unaware that FS25/2 existed, treating a publicly documented FCA action as unknowable. Either version leaves the team without accurate information about which supervisory expectations remain live.
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 Compliance team using the AI's account of the FS25/2 withdrawal programme to update its regulatory horizon-scanning or to advise business lines on which supervisory expectations remain live will either rely on fabricated dates and a fictitious two-stage structure, or conclude that no verified count is available when one is. Either outcome leaves the firm's regulatory mapping inaccurate — and if the firm continues treating withdrawn Dear CEO letters as live supervisory expectations, it may direct unnecessary compliance resource at obligations the FCA has formally retired.

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 4. Fair value assessment — quantification of non-monetary benefits Next finding → Finding 6. FCA senior officials' public statements on first-year Consumer Duty compliance

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 — FS25/2 — Life 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/life_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

APA 7th edition

RegLeg Specialist Panel. (2026). FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2 [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/life_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2 [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/life_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     = {FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2},
  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/life_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/}
}

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