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I realise this may be an unpopular view, but regardless of the adequacy of CCMS, I'm concerned at the approach taken by the firm here. They must surely know that they can delegate to grant emergency representation for the client and then have 5 days in which to submit the application.

If they can't get it in within the 5 days, they can explain the delay as down to system issues and ask the LAA to accept the application late (risky I know, if the LAA decide not to play ball)

Alternatively, if there is an ongoing problem with the system, they can ask for a contingency reference and submit a paper application.

Any of the above is better than leaving a client without representation, in my view