Is consumer testing of communications a mandatory requirement under the Consumer Duty? What does PRIN 2A.5 require versus what FG22/5 recommends on this point?
The model cited a specific rule reference, PRIN 2A.5.10R, as imposing a testing requirement "where appropriate." The FCA's actual rules in PRIN 2A.5 set an outcome obligation (delivering good consumer understanding) without prescribing consumer testing as a specific method. The recommendation to consider consumer testing appears in FG22/5, which is guidance rather than a binding rule. The model cross-referenced the wrong instrument type and attributed a specific rule citation that does not map to the FCA's text in the way described.
This finding implicates the model's cross-referencing between binding rules and non-binding guidance within the FCA Handbook. The model cited a specific rule reference (PRIN 2A.5.10R) as the basis for a testing requirement that actually appears in FG22/5 guidance. This is a rule/guidance conflation error: attributing the normative force of a binding rule to a provision that is guidance-level. This class of error is particularly impactful for compliance users who need to distinguish what they must do from what the FCA recommends.
A targeted eval checking whether the model correctly attributes 'R', 'G', and 'E' provisions to the right normative level would surface this pattern systematically across the FCA Handbook and analogous structured rulebooks at other regulators.
Retail Banking compliance teams preparing PRIN 2A.5 monitoring frameworks need to distinguish the rule from FG22/5 guidance. The model's specific PRIN 2A.5.10R citation as a binding consumer-testing requirement, if adopted in policy, creates an obligation the FCA has not imposed and locks the firm into a methodology that exceeds what the rule asks. Cost overhang and a hard-to-reverse policy commitment follow.
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). "Consumer testing of communications — rule versus guidance — Retail Banking × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/sectors/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/
RegLeg Specialist Panel. (2026). Consumer testing of communications — rule versus guidance [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/sectors/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/
RegLeg Specialist Panel, Consumer testing of communications — rule versus guidance [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/sectors/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/.
@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q007,
author = {RegLeg Specialist Panel},
title = {Consumer testing of communications — rule versus guidance},
year = {2026},
publisher = {RegLegBrief AI Hallucination Research},
note = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007},
url = {https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/sectors/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/}
}
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.