An SRA investigation into the conduct of the First and Second Respondent commenced in October 2018 following complaints in relation to the handling by the firm of high-cost short term credit (“Pay Day Loan”) claims.

The conclusions of the SRA investigation were that the First and Second Respondent had made misleading statements to clients during the Firms onboarding process and they also failed to obtain clients informed consent to submit complaints and claims on their behalf. They furthermore failed properly to assess the merits of their clients’ claims and complaints.
It was identified separately that the Firm had received five payments, totalling £230,500.00 into its client bank account in relation to property purchases on behalf of clients based outside of the jurisdiction.

This brought about an allegation (against the First Respondent only) that the Firm had failed to conduct any or adequate Client Due Diligence as required by the MLRs 2017 in relation to the proposed purchases on behalf of those international clients.

In respect of Allegations 1 and 2 against the First and Second Respondent the Tribunal found these allegations not proved against either of the Respondents.

In respect of Allegation 3 against the First Respondent only the Tribunal found this allegation not proved.

The Tribunal found no allegations proved against either Respondent and therefore imposed no sanction in respect of either the First or Second Respondent.