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With all due respect David C, you have to decide which it is. In one breath, you say that this sort of behavior is indefensible (correct!), but then you go on to blame it on the cost of compliance etc. Well, sorry, but there can be no excuse for playing fast and loose with clients' money - if you can't afford to stay in practice, jack it in and go and do something else. This is as black and white for solicitors as it gets!