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From the figures mentioned in these comments, it seems the SRA is pretty even handed in its approach, even though, as one has noted, these sort of fines and sanctions will more seriously affect a smaller firm than a larger one. Another consideration may be that in smaller firms breaches of this sort may be much more likely to recur, in that there are far fewer staff, and a higher proportion will have been complicit in the wrongdoing.

I would be interested to know how Clyde's internal processes operated in this case, and when the COFA and COLP became aware. This is never likely to be public, but it would be educational nonetheless. It must be virtually impossible for any COLP or COFA in a firm of this size to be aware of everything, so there must be heavy reliance on proper procedure and education. What, I wonder, went wrong?