Practitioners — Accountants (CA/PA) · Last updated 28 May 2026 · methodology v2.1 · Hallucination Register

Quantification of non-monetary benefits in fair value assessments

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008

AI's failure:Inference Drift Risk for Accountants (CA/PA):Regulatory enforcement / professional liability exposure

What the RLB Specialist Panel found

2. Quantification of non-monetary benefits in fair value assessments

Question (paraphrased to protect IP): Does the Consumer Duty require firms to quantify non-monetary benefits as part of a fair value assessment, and what methodology does the FCA expect?
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. One stated that quantification is encouraged where feasible and that qualitative assessment is acceptable only where quantification is impractical — framing quantification as the preferred approach. Another stated that firms must go beyond qualitative description and provide substantiated comparisons, implying a higher standard than the FCA actually sets.
What the regulator actually says: The FCA does not expect firms to quantify non-monetary costs and benefits as part of the fair value assessment process, but firms should undertake some form of qualitative assessment.
Why the AI went wrong: AI tools appear to have upgraded a clear "does not expect" into an active encouragement, and then applied conditions to what the FCA treats as an unconditional obligation (qualitative assessment). The effect is to impose a higher and incorrect standard on firms — one that misrepresents both what is required and what is optional.
Cited source(s):
https://handbook.fca.org.uk/handbook/PRIN/2A/4.html — Pretextual
https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf — Pretextual
https://www.fca.org.uk/publications/good-and-poor-practice/consumer-duty-find... — Pretextual

Impact for Accountants (CA/PA) in the United Kingdom advising on the Consumer Duty (PS22/9 + PRIN 2A)

Accountants supporting fair-value assessment work need to ground methodology choices in the regulator's actual expectation, which is qualitative-only with no quantification mandate. The model's reversal of this position, if adopted in a financial-reporting or audit-support memo, would justify quantification work the FCA has expressly not required, inflating both cost and audit scope.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q008-Opus47 Claude Opus 4.7 (web search on)
RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q008-Sonnet46 Claude Sonnet 4.6 (web search on)

This finding also affects

← Previous finding Charity and micro-enterprise scope under the Consumer Duty

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.

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008

Plain text Download

RegLeg Specialist Panel (2026). "Quantification of non-monetary benefits in fair value assessments — Practitioners — Accountants (CA/PA)." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008. RegLegBrief AI Hallucination Research, published 2026-05-28. https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/practitioners/accountants-ca-pa/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/

APA 7th edition Download

RegLeg Specialist Panel. (2026). Quantification of non-monetary benefits in fair value assessments [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/practitioners/accountants-ca-pa/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, Quantification of non-monetary benefits in fair value assessments [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008], RegLegBrief AI Hallucination Research (May 28, 2026), https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/practitioners/accountants-ca-pa/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/.

BibTeX Download

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q008,
  author    = {RegLeg Specialist Panel},
  title     = {Quantification of non-monetary benefits in fair value assessments},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008},
  url       = {https://reglegbrief.com/regulators/j3/gb/FCA/CONSUMER-DUTY-PS22-9/practitioners/accountants-ca-pa/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/}
}

← Back to case study summary Case study detail →

About Citation IDs →

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.