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I am not sure what to make of this... on the one hand £124k seems an amazingly good investment for the level of profits this firm appears to have made, so in other words the fine seems on the low side.

But on the other hand, what actually is the misconduct here? Sending out misleading letters seems to be par for the course for companies who use junk mail for marketing, but in this case were the letters even misleading? Based on what the article says, it is true that they contained 'important information' as they gave the recipients the ability to make money they hadn't previously realised they were entitled to. The firm was authorised and regulated by the SRA, so that isn't misleading. And as for not employing anyone with the job title 'professional forensic investigators' at the time the letters went out, it is hardly an unusual business model to drive up demand before building up capacity to deliver, assisted with some marketing puffery on the way.

So I can't help but wonder if it was the the failure to do due diligence on their clients that was the main reason behind the fine.

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