Retail Banking × Compliance — United Kingdom · published 2026-05-26 · methodology v2.1

Changes between CP21/36 consultation and the final rules in PS22/9

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017

What the RLB Specialist Panel found

8. Changes between CP21/36 consultation and the final rules in PS22/9

Question (paraphrased to protect IP): Were there significant differences between the Consumer Duty as proposed in CP21/36 and the final rules in PS22/9? What specific provisions were changed?
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 on this question. Both AI responses provide lists of specific differences between the CP21/36 draft and the final PS22/9 rules — covering areas including implementation timelines, foreseeable harm wording, outcomes monitoring scope, product governance alignment, and the decision not to introduce a private right of action — presented with apparent confidence and specific detail.
What the regulator actually says: The specific differences between the CP21/36 draft and the PS22/9 final rules were not reliably recoverable by independent verification for this question. While some elements (such as the two-stage implementation timeline and the private right of action decision) are broadly documented in public commentary, the specific framing of rule wording changes cannot be independently confirmed.
Why the AI went wrong: Both AI responses presented detailed, specific claims about regulatory drafting changes without acknowledging any uncertainty, in a context where the precise differences are not reliably traceable through standard public sources. The AI's apparent confidence is itself the risk: a Compliance team reading this output would have no signal that the characterisation of specific wording changes may be reconstruction rather than verified fact.
Cited source(s):
https://www.fca.org.uk/publication/consultation/cp21-36.pdf — Pretextual
https://www.womblebonddickinson.com/uk/insights/articles-and-briefings/consum... — Pretextual

Impact for this audience

A Compliance team that accepts the AI's confident characterisation of specific CP21/36-to-PS22/9 wording changes as fact may build those characterisations into regulatory history documents, training materials, or briefing papers that cannot be verified against primary sources. The specific risk is that the AI's framing of rule wording evolution — such as how the foreseeable harm standard was modified — could affect how staff understand the current rule's scope. If an AI's reconstruction of a wording change suggests the final rule is narrower or broader than it actually is, that misunderstanding propagates through every training session and policy document that relies on the historical narrative the AI provided.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q017-Opus47 Claude Opus 4.7 (web search on)
RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q017-Sonnet46 Claude Sonnet 4.6 (web search on)

This finding also affects

← Previous finding Finding 7. FCA public statements on Consumer Duty compliance in year one Next finding → Finding 9. Which pre-Consumer Duty Dear CEO letters remain in force

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). "Changes between CP21/36 consultation and the final rules in PS22/9 — Retail Banking × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017. 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-v1-017/

APA 7th edition

RegLeg Specialist Panel. (2026). Changes between CP21/36 consultation and the final rules in PS22/9 [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Changes between CP21/36 consultation and the final rules in PS22/9 [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017], 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-v1-017/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q017,
  author    = {RegLeg Specialist Panel},
  title     = {Changes between CP21/36 consultation and the final rules in PS22/9},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017},
  url       = {https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/}
}

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