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 risk teams monitoring consumer-understanding outcomes under PRIN 2A.5 need to know what the rule actually requires versus what FG22/5 recommends. The model's blurring of the two raises risk-monitoring scope without any underlying rule requirement.
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). "Finding#2 . Confused FG22/5 guidance with PRIN 2A.5 rule on consumer testing — Retail Banking × Risk — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007. RegLegBrief AI Hallucination Research, published 2026-06-11. https://reglegbrief.com/regulators/j3/gb/fca/consumer-duty-ps22-9/sectors/retail_banking/risk/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/
RegLeg Specialist Panel. (2026). Finding#2 . Confused FG22/5 guidance with PRIN 2A.5 rule on consumer testing [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/risk/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/
RegLeg Specialist Panel, Finding#2 . Confused FG22/5 guidance with PRIN 2A.5 rule on consumer testing [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007], RegLegBrief AI Hallucination Research (June 11, 2026), https://reglegbrief.com/regulators/j3/gb/fca/consumer-duty-ps22-9/sectors/retail_banking/risk/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 = {Finding#2 . Confused FG22/5 guidance with PRIN 2A.5 rule on consumer testing},
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/risk/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.