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I'm not trying to be clever after the event, but isn't this a really basic error? You cant just turn over client files to any firm who may want to purchase / review the files. You need client consent. I fully appreciate that this makes it very difficult to undertake due diligence unless of course you tip off all the clients that you are planning on selling up which has its own consequences. What is staggering is that S&G spunked £31 million on due diligence and still could not get this right.