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

Which pre-Consumer Duty Dear CEO letters remain in force

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

What the RLB Specialist Panel found

9. Which pre-Consumer Duty Dear CEO letters remain in force

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 Has the FCA withdrawn any letters that previously set consumer protection expectations?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: Multiple AI tools gave significantly different incorrect responses on this question. One AI stated that the FCA retired approximately 90 Dear CEO letters in April 2025 and over 100 multi-firm and thematic reports in August 2025, presenting these as two separate exercises. A second AI declined to provide any count or list, stating it could not identify verified information from available sources.
What the regulator actually says: From FS25/2 (March 2025): the FCA reviewed all Dear CEO letters pre-dating its 2022–25 strategy and withdrew more than 90 such letters, alongside clearing over 100 old multi-firm reports. These are no longer live supervisory expectations.
Why the AI went wrong: One AI fabricated the dates of both exercises and invented a phased structure that does not reflect the single documented event in March 2025. The other AI failed to identify FS25/2 as the relevant document entirely — the same gap that appears in Finding 6 — demonstrating a consistent blind spot for this specific FCA publication across multiple AI tools. For a Compliance team trying to determine which historic supervisory expectations still bind the firm, neither response is usable.
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 Compliance Teams in Retail Banking Sector in United Kingdom working with the AI Hallucinations Affecting Compliance at Retail Banking Firms in the United Kingdom

The inability to accurately identify which Dear CEO letters remain in force after Consumer Duty implementation has direct operational consequences for a Retail Banking firm's compliance programme. If the firm's Compliance team cannot identify FS25/2 as the controlling document for this question, it may waste resource attempting to identify live expectations from a larger set of letters than actually applies — or it may miss a withdrawn letter that was previously shaping an internal process, leaving that process unchanged when it could be simplified.

The FCA has been clear that FS25/2 was intended to reduce complexity for firms; a Compliance team that does not know this document exists cannot benefit from that clarity, and the process inefficiencies compound over time.

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)

← Previous finding Changes between CP21/36 consultation and the final rules in PS22/9

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

Plain text Download

RegLeg Specialist Panel (2026). "Which pre-Consumer Duty Dear CEO letters remain in force — Retail Banking × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020. 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-v1-020/

APA 7th edition Download

RegLeg Specialist Panel. (2026). Which pre-Consumer Duty Dear CEO letters remain in force [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/

Bluebook / OSCOLA (US + UK legal) Download

RegLeg Specialist Panel, Which pre-Consumer Duty Dear CEO letters remain in force [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q020], 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-v1-020/.

BibTeX Download

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q020,
  author    = {RegLeg Specialist Panel},
  title     = {Which pre-Consumer Duty Dear CEO letters remain in force},
  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/audiences/sectors/gb/retail_banking/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-020/}
}

← Back to case study summary Case study detail →

About Citation IDs →