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Stephen. You state that "Secondly, clients or ‘consumers’ (to use regulators’ preferred terminology) can experience crises in their lives, be irrational or just be wrong. Some clients can and will develop threatening behaviour"

The model for handling complaints should absolutely provide guidance for handling complaints you believe are unmeritorious.

By handling complaints in a standardised way you (and other regulated lawyers) will make it much easier for LeO to get to grips with the substantive issues.

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