Retail Banking × Compliance — United Kingdom · updated 2026-05-26 · methodology v2.1

FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013

What the RLB Specialist Panel found

6. FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2

Question (paraphrased to protect IP): Has the FCA withdrawn any pre-Consumer Duty Dear CEO letters following implementation, and if so how many?
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 significantly different incorrect responses on this question. One AI fabricated two separate withdrawal events — placing approximately 90 Dear CEO letters as retired in April 2025 and a further tranche of multi-firm reports as retired in August 2025 — while omitting the FCA document that records the actual event. A second AI declined to provide any figure at all, stating it could not identify a definitive public list of withdrawn letters.
What the regulator actually says: In FS25/2 (March 2025), the FCA removed more than 90 pre-Consumer Duty Dear CEO letters and cleared over 100 old multi-firm reports. Both categories were addressed in a single exercise reported under that document reference.
Why the AI went wrong: One AI invented dates and a phased structure for an event that occurred as a single, documented action in March 2025, while also failing to reference FS25/2. The other AI appears to have been entirely unaware of FS25/2 as the relevant document. Both failures leave a Compliance team without reliable information about which historic supervisory letters remain live, which is directly relevant to scoping Consumer Duty obligations.
Cited source(s):
https://www.fca.org.uk/news/news-stories/fca-simplifies-supervisory-letters — Pretextual
https://www.fca.org.uk/news/news-stories/next-steps-consumer-duty-rule-review — Pretextual

Impact for Compliance Teams in Retail Banking Sector in United Kingdom working with the AI Hallucinations Affecting Compliance at Retail Banking Firms in the United Kingdom

Not knowing which historic Dear CEO letters remain live supervisory expectations is a direct compliance risk. If a Retail Banking firm treats a withdrawn letter as still binding — because its Compliance team received AI output that either fabricated a later withdrawal date or could not confirm withdrawal at all — it may be designing processes around obsolete expectations. Conversely, if the firm assumes all pre-2022 letters were withdrawn when some remain in force, it may inadvertently drop still-active supervisory requirements.

The FCA's March 2025 FS25/2 exercise was specifically designed to provide clarity on this question; AI tools that are unaware of or misrepresent that document leave Compliance teams without reliable guidance on scope.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q013-Opus47 Claude Opus 4.7 (web search on)
RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q013-Sonnet46 Claude Sonnet 4.6 (web search on)

← Previous finding Quantification of non-monetary benefits in fair value assessments Next finding → FCA public statements on Consumer Duty compliance in year one

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-Q013

Plain text Download

RegLeg Specialist Panel (2026). "FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2 — Retail Banking × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

APA 7th edition Download

RegLeg Specialist Panel. (2026). FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2 [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2 [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/.

BibTeX Download

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q013,
  author    = {RegLeg Specialist Panel},
  title     = {FCA withdrawal of pre-Consumer Duty Dear CEO letters — FS25/2},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q013},
  url       = {https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-013/}
}

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