Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?
The FCA's feedback statement FS25/2 was published in March 2025 and announced the withdrawal of both categories simultaneously. The model re-dated the Dear CEO letter withdrawal to April 2025 and fabricated a separate August 2025 tranche for multi-firm reports that does not exist in the regulator's record. The model appears to have split a single announced action into two sequential events, adding invented dates for each.
This finding implicates the model's temporal reasoning on regulatory events: it split a single March 2025 announcement (FS25/2) into two events across April and August 2025. This suggests the model had partial training coverage of the FS25/2 publication and filled the gaps with invented dates. The fabricated August 2025 tranche is particularly notable because it post-dates the model's likely training window: this may be the model generating a plausible continuation of a partial knowledge record rather than retrieving a real event.
The same fabricated timeline appears under a differently framed question (Finding#9), confirming this is a persistent internal model representation rather than a random generation error. Correction pairs targeting FS25/2 directly would be the most efficient remediation.
Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?
The FCA's feedback statement FS25/2 was published in March 2025 and announced the withdrawal of both categories simultaneously. The model re-dated the Dear CEO letter withdrawal to April 2025 and fabricated a separate August 2025 tranche for multi-firm reports that does not exist in the regulator's record. The model appears to have split a single announced action into two sequential events, adding invented dates for each.
This finding implicates the model's temporal reasoning on regulatory events: it split a single March 2025 announcement (FS25/2) into two events across April and August 2025. This suggests the model had partial training coverage of the FS25/2 publication and filled the gaps with invented dates. The fabricated August 2025 tranche is particularly notable because it post-dates the model's likely training window: this may be the model generating a plausible continuation of a partial knowledge record rather than retrieving a real event.
The same fabricated timeline appears under a differently framed question (Finding#9), confirming this is a persistent internal model representation rather than a random generation error. Correction pairs targeting FS25/2 directly would be the most efficient remediation.
Financial Advisers who advise on FCA supervisory expectations need to know which historic Dear CEO letters remain live. A practitioner who relies on an AI tool that either fabricates two separate retirement events or claims the information is unavailable will be unable to tell their client which pre-Duty supervisory expectations continue to apply. This matters in practice: if a firm continues to treat a withdrawn Dear CEO letter as a live expectation, it may incur unnecessary compliance costs or misalign its processes around a document the FCA no longer endorses.
The FCA's published FS25/2 is the authoritative reference — and both AI responses failed to identify or accurately represent it.
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.
RegLeg Specialist Panel (2026). "FCA withdrawal of pre-Consumer Duty Dear CEO letters — volume and timing — Practitioners — Financial Advisers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/regulators/j3/GB/FCA/CONSUMER-DUTY-PS22-9/practitioners/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/
RegLeg Specialist Panel. (2026). FCA withdrawal of pre-Consumer Duty Dear CEO letters — volume and timing [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/GB/FCA/CONSUMER-DUTY-PS22-9/practitioners/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/
RegLeg Specialist Panel, FCA withdrawal of pre-Consumer Duty Dear CEO letters — volume and timing [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/regulators/j3/GB/FCA/CONSUMER-DUTY-PS22-9/practitioners/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/.
@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 — volume and timing},
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/regulators/j3/GB/FCA/CONSUMER-DUTY-PS22-9/practitioners/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/}
}
Every finding on this page compares an AI subject's account of the rule against the regulator's verbatim text from the regulator's own portal. Both are linked. Each delta, its root causes, and impact analysis are documented and published with immutable Citation IDs.