David Ebert LLP

Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision

David Ebert LLP admitted four allegations: failing to comply with the SRA Transparency Rules (rules 1.1 and 2.1), failing to comply with conditions of authorisation imposed by an SRA Adjudicator, and failing to have designated COLP and COFA over extended periods. The Tribunal found these were not deliberate breaches but arose during a period of firm transformation. No dishonesty was alleged or found. On an agreed outcome dealt with on the papers, the Tribunal ordered the firm to pay a fine of £20,723.20 and costs of £10,000, finding a fine proportionate and in the public interest.

Duties found breached:

• Competence
• Cooperate openly with regulators
• Good faith and courtesy to colleagues
• No conflict between current clients
• Not misrepresent regulated status

Aggravating factors:

• Firm was aware of the breaches but did not act quickly enough to resolve them
• Took too long to rectify problems despite repeated SRA correspondence
• Attention of COLP and senior team diverted from issues of core importance

Mitigating factors:

• Breaches were not deliberate but caused by a period of transformation/administrative challenges
• No financial or other advantage gained from the breaches
• No harm caused to any person and no advantage taken of any person
• Full co-operation with the SRA throughout the investigation and proceedings
• Open and transparent dealings with the SRA, including early admission of the breaches