Practitioners — Lawyers · updated 2026-05-26 · methodology v2.1

Which FCA Dear CEO letters remain in force after Consumer Duty implementation

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020

AI's failure:Inference Drift Risk for Lawyers:Operational decisions based on a fabricated regulator record

What the RLB Specialist Panel found

10. Which FCA Dear CEO letters remain in force after Consumer Duty implementation

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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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: AI tools again gave two types of wrong answer on this question. One tool described the withdrawal programme as two separate tranches — approximately 90 Dear CEO letters retired in April 2025, and more than 100 multi-firm and thematic reports retired in August 2025 — with no reference to the relevant FCA publication. Another tool stated it could not identify a verified count or a complete current list from available sources.
What the regulator actually says: Under FS25/2 (March 2025), the FCA reviewed all Dear CEO letters pre-dating its 2022–25 strategy and withdrew more than 90 such letters, which are no longer live supervisory expectations.
Why the AI went wrong: One AI tool fabricated a two-tranche withdrawal timeline with dates that do not correspond to any FCA publication. The other was unaware of FS25/2 entirely and gave no answer. Both failures leave a lawyer unable to advise accurately on which supervisory expectations a regulated firm must currently observe, a gap that carries direct consequences for any client whose compliance programme is built around a Dear CEO letter that may no longer be live.
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 Lawyers in the United Kingdom advising on the Consumer Duty (PS22/9 + PRIN 2A)

The same fabricated April and August 2025 timeline appears under a differently framed question, which is a strong signal for a lawyer that the model has an internalised but wrong account of FS25/2. A litigation or enforcement-defence brief that cites the AI's reconstruction risks being undermined by the regulator's own published record. The professional liability point is that this is not a one-off slip; the model reproduces the error consistently, so any brief, opinion, or supervisory letter that imports it will be wrong in the same way.

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 Scope exclusions — reinsurance, large-risk contracts, and group insurance distribution

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-Q020

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, Which FCA Dear CEO letters remain in force after Consumer Duty implementation [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/regulators/j3/gb/fca/consumer-duty-ps22-9/practitioners/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/.

Plain text Download

RegLeg Specialist Panel (2026). "Which FCA Dear CEO letters remain in force after Consumer Duty implementation — Practitioners — Lawyers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/regulators/j3/gb/fca/consumer-duty-ps22-9/practitioners/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

APA 7th edition Download

RegLeg Specialist Panel. (2026). Which FCA Dear CEO letters remain in force after Consumer Duty implementation [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/regulators/j3/gb/fca/consumer-duty-ps22-9/practitioners/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

BibTeX Download

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Which FCA Dear CEO letters remain in force after Consumer Duty implementation},
  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/regulators/j3/gb/fca/consumer-duty-ps22-9/practitioners/lawyers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

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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.