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I second AR's comments.
What is needed is a set of clear and unambiguous rules.
Outcomes focussed regulation is not sensible because it requires the application of the retrospectoscope.
As I've said before, outcomes-focussed regulation means that we are being told to drive from Cardiff to Bristol without exceeding the speed limits. However, we are not to be told the speed limits until after we've reached our destination. But we will be punished if we exceed them.
This proposed fudge about client money and office money is to the detriment of our clients, whose interests I have always understood to be paramount.
The Holy Grail appears to the SRA to be no regulation, no control, cheap services and the devil take the hindmost. The abandonment of the compulsory submission of the accountant's certificate is the worst example. Don''t bother to file a certificate unless you're on the fiddle. We're sure you will tell us if you are.
I could go on, and probably will.