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Practitioners — Financial Advisers · updated 2026-05-26 · methodology v2.1
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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 Financial Advisers:Regulatory enforcement / professional liability exposure
What the RLB Specialist Panel found

5. 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? 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 of non-monetary benefits is "encouraged where feasible" but that qualitative assessment is acceptable where quantification is impractical. A second stated that firms must "go beyond qualitative description" and provide substantiated comparisons.
  • What the regulator actually says: The FCA does not expect firms to quantify non-monetary costs and benefits as part of its fair value assessment process, but firms should undertake some form of qualitative assessment.
  • Why the AI went wrong: Both AI responses inverted the FCA's actual position. The FCA guidance is explicit that quantification is not expected — qualitative assessment is what the regulator requires. One AI tool converted this permissive non-expectation into positive encouragement; the other directly contradicted it by saying firms must move beyond qualitative description. A practitioner who follows either version would design a more burdensome internal process than the FCA actually requires, and may misrepresent their obligations in a regulatory submission.
  • 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 Financial Advisers in the United Kingdom advising on the Consumer Duty (PS22/9 + PRIN 2A)

Financial advisers designing fair-value assessment templates for retail products should not import the AI's reversed methodology. The FCA expressly does not require quantification of non-monetary costs and benefits; the model's affirmation creates phantom analytical work that distracts from the actual regulator-mandated qualitative assessment. Advisers who follow the model's framing will overbuild the fair-value template and may still under-deliver on the qualitative assessment that the FG22/5 guidance actually requires.

References — raw findings (per AI model)
This finding also affects
← Previous finding Consumer testing of communications — mandatory rule or guidance recommendation? Next finding → FCA withdrawal of pre-Consumer Duty Dear CEO letters — volume and timing
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 — Financial Advisers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q008. 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-v1-008/
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/financial-advisers/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 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-v1-008/.
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/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-008/}
}
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