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

Which Dear CEO letters remain live after FS25/2?

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

What the RLB Specialist Panel found

8. Which Dear CEO letters remain live after FS25/2?

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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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 fabricated a two-stage withdrawal programme, placing letter retirements in April 2025 and report retirements in August 2025. The other stated there is no publicly available consolidated list identifying which letters have been formally withdrawn, that it cannot provide a verified count, and that it is unable to confirm how many letters remain in force as at 2025.
What the regulator actually says: Under FS25/2 (March 2025), the FCA reviewed all Dear CEO letters pre-dating the 2022–25 strategy and withdrew more than 90 such letters. These letters are no longer live supervisory expectations.
Why the AI went wrong: The same failure pattern observed in Finding 5 repeats here with different AI tools: one fabricated an incorrect timeline and event structure; the other was unaware of FS25/2 entirely, treating a publicly documented and significant regulatory action as inaccessible information. A Compliance team asking this question to determine which historical supervisory expectations still bind the firm would receive either false information or a non-answer — neither of which supports accurate regulatory mapping.
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

A Compliance team using the AI's account of FS25/2 to advise on which Dear CEO letters remain live will either work from a fabricated date and event structure or proceed without any verified count — in both cases leaving the firm's regulatory mapping of active supervisory expectations incomplete or incorrect. If legacy Dear CEO letters that have been formally withdrawn are still treated as binding expectations in training materials or governance frameworks, the firm bears the ongoing cost of over-compliance and cannot demonstrate accurate horizon-scanning to the FCA or its board.

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 7. Scope exclusions — reinsurance, group insurance, and large-risk 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). "Which Dear CEO letters remain live after FS25/2? — Life 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/life_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). Which Dear CEO letters remain live after FS25/2? [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/life_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Which Dear CEO letters remain live after FS25/2? [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], 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-v1-020/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Which Dear CEO letters remain live after 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/life_insurance/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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