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

Which pre-Consumer Duty Dear CEO letters remain in force

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

What the RLB Specialist Panel found

9. Which pre-Consumer Duty Dear CEO letters remain in force

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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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 significantly different incorrect responses on this question. One AI stated that the FCA retired approximately 90 Dear CEO letters in April 2025 and over 100 multi-firm and thematic reports in August 2025, presenting these as two separate exercises. A second AI declined to provide any count or list, stating it could not identify verified information from available sources.
What the regulator actually says: From FS25/2 (March 2025): the FCA reviewed all Dear CEO letters pre-dating its 2022–25 strategy and withdrew more than 90 such letters, alongside clearing over 100 old multi-firm reports. These are no longer live supervisory expectations.
Why the AI went wrong: One AI fabricated the dates of both exercises and invented a phased structure that does not reflect the single documented event in March 2025. The other AI failed to identify FS25/2 as the relevant document entirely — the same gap that appears in Finding 6 — demonstrating a consistent blind spot for this specific FCA publication across multiple AI tools. For a Compliance team trying to determine which historic supervisory expectations still bind the firm, neither response is usable.
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

The inability to accurately identify which Dear CEO letters remain in force after Consumer Duty implementation has direct operational consequences for a Retail Banking firm's compliance programme. If the firm's Compliance team cannot identify FS25/2 as the controlling document for this question, it may waste resource attempting to identify live expectations from a larger set of letters than actually applies — or it may miss a withdrawn letter that was previously shaping an internal process, leaving that process unchanged when it could be simplified. The FCA has been clear that FS25/2 was intended to reduce complexity for firms; a Compliance team that does not know this document exists cannot benefit from that clarity, and the process inefficiencies compound over time.

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

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 pre-Consumer Duty Dear CEO letters remain in force — Retail Banking × 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/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition

RegLeg Specialist Panel. (2026). Which pre-Consumer Duty Dear CEO letters remain in force [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Which pre-Consumer Duty Dear CEO letters remain in force [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], 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-v1-020/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Which pre-Consumer Duty Dear CEO letters remain in force},
  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/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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