Retail Banking × 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

6. 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Question (paraphrased to protect IP): Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?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 significantly different incorrect responses on this question. One AI fabricated two separate withdrawal events — placing approximately 90 Dear CEO letters as retired in April 2025 and a further tranche of multi-firm reports as retired in August 2025 — while omitting the FCA document that records the actual event. A second AI declined to provide any figure at all, stating it could not identify a definitive public list of withdrawn letters.
What the regulator actually says: In FS25/2 (March 2025), the FCA removed more than 90 pre-Consumer Duty Dear CEO letters and cleared over 100 old multi-firm reports. Both categories were addressed in a single exercise reported under that document reference.
Why the AI went wrong: One AI invented dates and a phased structure for an event that occurred as a single, documented action in March 2025, while also failing to reference FS25/2. The other AI appears to have been entirely unaware of FS25/2 as the relevant document. Both failures leave a Compliance team without reliable information about which historic supervisory letters remain live, which is directly relevant to scoping Consumer Duty obligations.
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

Not knowing which historic Dear CEO letters remain live supervisory expectations is a direct compliance risk. If a Retail Banking firm treats a withdrawn letter as still binding — because its Compliance team received AI output that either fabricated a later withdrawal date or could not confirm withdrawal at all — it may be designing processes around obsolete expectations. Conversely, if the firm assumes all pre-2022 letters were withdrawn when some remain in force, it may inadvertently drop still-active supervisory requirements. The FCA's March 2025 FS25/2 exercise was specifically designed to provide clarity on this question; AI tools that are unaware of or misrepresent that document leave Compliance teams without reliable guidance on scope.

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 5. Quantification of non-monetary benefits in fair value assessments Next finding → Finding 7. FCA public statements on Consumer Duty compliance in year one

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 — Retail Banking × 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/retail_banking/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/retail_banking/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/retail_banking/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/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/}
}

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