Corporate report

Annual Review of Insolvency Practitioner Regulation 2024

Published 10 June 2025

1. Overview

The Insolvency Service is an executive agency of the Department for Business and Trade (DBT) and helps deliver economic confidence by supporting those in financial distress, tackling financial wrongdoing and maximising returns to creditors.

Acting as oversight regulator of Insolvency Practitioners (IPs) on behalf of the Secretary of State for DBT, the Insolvency Service works with the insolvency profession ensuring that professional and regulatory standards are maintained or improved where necessary, and that professional misconduct is addressed.

The Secretary of State, by Order, recognises independent professional bodies, known as the Recognised Professional Bodies (RPBs) for the purpose of authorising individuals to act as Insolvency Practitioners. Under the provisions of the Insolvency Act 1986, any individual who acts as a liquidator, trustee in bankruptcy, administrator, administrative receiver, a nominee or supervisor of a voluntary arrangement, or a trustee under a trust deed in Scotland must be authorised by an RPB to act as an Insolvency Practitioner.

During 2024, Insolvency Practitioners were regulated by four RPBs, in alphabetical order:

• Chartered Accountants Ireland (CAI)
• Insolvency Practitioners Association (IPA)
• Institute of Charted Accountants in England and Wales (ICAEW)
• Institute of Chartered Accountants of Scotland (ICAS)

The Insolvency Service and the RPBs work to achieve regulatory objectives of the Insolvency Practitioner regime, as set out in the Insolvency Act 1986. These are:

• Having a system of regulating persons acting as Insolvency Practitioners that secures fair treatment for persons affected by their acts or omissions, reflects the regulatory principles and delivers consistent outcomes.
• Encouraging an independent and competitive Insolvency Practitioner profession, whose members provide high quality services at a fair and reasonable cost, act transparently and with integrity, and consider the interests of all creditors in any particular case.
• Promoting the maximisation of the value of returns to creditors and the promptness making those returns.
• Protecting and promoting the public interest.

The Insolvency Service actively monitors the RPBs through a combination of desktop monitoring, inspection visits and themed reviews, details of which are published on the Agency’s website.

The Secretary of State has powers to direct or reprimand an RPB if they believe that it is acting in a way that is having an adverse impact on the achievement of the objectives, and can also, if appropriate, make enquiries and take direct action against Insolvency Practitioners.

The Insolvency Service operates the Complaints Gateway in accordance with the Memorandum of Understanding between the Insolvency Service, the Department of Economy and the RPBs. The Gateway acts as a single point of contact for making complaints about the conduct of Insolvency Practitioners, regardless of which RPB they are authorised by. The Insolvency Service monitors the progress and outcomes of those complaints.

The Insolvency Service also conducts wider work to help achieve the regulatory objectives.

This report sets out various data relating to regulatory activity during 2024 in respect of functions and obligations covered by the Insolvency Act 1986 and the Complaints Gateway Memorandum of Understanding. The data presented here are derived from information obtained annually from the RPBs and the Complaints Gateway.

2. Legislative and regulatory developments and activities

The regulatory and legislative landscape saw a number of significant developments during 2024.

2.1 Legislation

The Insolvency Practitioners (Amendment and Transitional Provisions) Regulations 2024 came into force on 1 December 2024, changing insolvency bonding arrangements, with key changes including an increase of the General Penalty Sum from £250,000 to £750,000, new minimum statutory requirements for bonds, and a run-off period of at least two years from release or discharge from office.

The Secretary of State increased the levy charged to RPBs in respect of each authorised Insolvency Practitioner to cover the rising costs of oversight regulation. The fee rose from £470 to £610, with effect from of 1 January 2025.

The Government made changes to the Debt Relief Order process to help people in problem debt get a fresh start with their finances and access the support they need. The £90 administration fee was permanently removed on 6 April 2024, and on 28 June 2024 the maximum debt threshold was increased from £30,000 to £50,000. By the end of 2024, the number of DRO applications increased from around 2,500 to 4,000 per month.

A range of other government bodies also made changes affecting the Insolvency profession:

Companies House began implementing reforms set out by the Economic Crime and Corporate Transparency Act 2023 in March 2024 in order to combat economic crime and improve transparency over UK companies and other legal entities. The reforms include new reporting and filing requirements on the insolvency profession, as well as more extensive legal gateways for data sharing with law enforcement, government bodies and the private sector.

On 24 July 2024, the Leasehold and Freehold Reform Act 2024 placed new reporting obligations on Insolvency Practitioners in respect of building and resident safety for higher-risk and relevant buildings.

The FCA’s Consumer Duty, introduced in 2023, set new standards for consumer care and protection for new and existing products and services. From 31 July 2024, the Consumer Duty started applying to the products and services of firms held in closed books. The rules require firms to consider the needs, characteristics and objectives of their customers.

The Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024, laid on 14 November 2024, expanded reporting obligations in relation to financial sanctions imposed by OFSI, to include Insolvency Practitioners from 14 May 2025.

The Information Sharing (Disclosure by the Registrar) Regulations 2024 came into force on 20 December 2024 to enable the registrar of companies to share certain information with Insolvency Practitioners and others involved in insolvency proceedings.

2.2 Regulation

The Joint Insolvency Committee (JIC) continued its work on developing and improving insolvency standards to maintain and promote consistency across the profession. In 2024 the JIC revised two Insolvency Guidance Papers (IGPs) to ensure that they remain relevant to the current regulatory and legislative landscape.

The Succession Planning IGP came into force on 1 August 2024, with its focus on contingency and continuity planning in a number of different scenarios.

Revisions to the Control of Cases IGP, which came into effect on 2 December 2024, recognised the move to a risk-based approach to monitoring and case management, the increased use of outsourcing and remote case processing and the growth of volume or large-scale case administration.

Three IGPs were also withdrawn in 2024:

• Bankruptcy – The Family Home, and Retention of Title were both withdrawn in August as JIC considered the guidance was no longer required due to the practice being widely accepted and embedded.
• Systems for control of accounting and other business records was withdrawn in December as no longer useful because of its main focus on hard copy records.

2.3 Individual Voluntary Arrangements (IVAs)

Addressing concerns about the IVA market continued as a priority for the Insolvency Service and regulators in 2024. As a result, there has been a particular focus on improving the quality of take-on procedures for IVAs over recent years.

Work has included new standards, monitoring guidance, action by the FCA and the Advertising Standards Authority, as well as increased consumer call monitoring, targeted inspections, and regulatory and disciplinary action taken by the RPBs.

On 17 October 2024, the Insolvency Service published the findings of an independent research it had commissioned to examine the IVA market’s compliance with take-on processes set out in the Statement of Insolvency Practice 3.1 and the IVA Protocol. The research found evidence of concerning levels of poor practice.

Following the publication, the Insolvency Service wrote to the RPBs requesting that they work with Insolvency Practitioners operating within the volume IVA sector to put in place comprehensive action plans to address poor practice: remedying significant shortcomings in relation to call recording, revising training to staff, and making improvements to their quality assurance systems.

In addition, in 2024 the Insolvency Service and the IVA Standing Committee started work on a new simplified IVA protocol and a clear facts document to better inform consumers of their options.

The Insolvency Service has continued to work with regulatory, advice and creditor bodies on further improvements to address concerns in the IVA market. 

Additionally, following the publication of the Response to Insolvency Service Official Statistics Consultation 2023, in 2024 the Insolvency Service increased the frequency of IVA Outcomes and Providers statistics from annual to quarterly, and expanded the monthly official statistics to show numbers of IVAs registered by firm each month, rather than only publishing annual numbers as was previously done.

2.4 Changes in RPB Regulations, Procedures and Bye-laws

CAI
On 21 March 2024, the Council of the Institute of Chartered Accountants Ireland approved a proposal to cease the regulation of Insolvency Practitioners in both Ireland and the UK. The formal process to revoke Chartered Accountants Ireland’s status as an RPB commenced during 2024.  All Insolvency Practitioners formerly members of CAI who are continuing in practice are now licensed and regulated by the remaining RPBs.

All current CAI Regulations are available on CAI’s website here.

ICAEW
Following a consultation on Professional Indemnity Insurance (PII) Regulations, ICAEW made changes to its professional indemnity insurance requirements, which came into force on 1 September 2024. The changes reflected the modern way firms are structured to ensure that the PII Regulations are fit for the future and provide greater protection to the public.

All current ICAEW Regulations are available on ICAEW’s website here.

ICAS
On 1 January 2024, ICAS introduced some minor wording changes to various Regulations. Changes to ICAS’s Professional Indemnity Insurance (PII) Regulations came into force on 1 September 2024.

All current ICAS Regulations are available on ICAS’s website here.

IPA
On 1 April 2024, changes to the IPA Regulatory Rules came into effect, following their adoption by its Board on 27 March 2024. This update permits members of the IPA’s Regulation Team as well as the Monitoring Team to issue Advisory Notices that recommend changes to an IP’s conduct or practice.

On 19 September 2024, the IPA’s new Articles of Association were approved at an Extraordinary General Meeting (EGM) and took effect on 1 January 2025. These revisions allow for greater flexibility while ensuring the clear separation between membership and regulatory functions, reversing changes made in 2019. This separation ensures that operational activities do not compromise the independence and objectivity of regulatory functions, which helps maintain public confidence in the IPA’s impartiality.

All current IPA Regulations are available on IPA’s website here.

2.5 Other developments

On 17 December 2024, the Insolvency Service published its independent CVL research report, a follow up to its 2022 First Review on the operation of the Insolvency (England and Wales) Rules 2016, reviewing the efficiency and effectiveness of the CVL process, and on pre-appointment expenses / fees in general.

The research found that in the majority of CVLs, realisable assets were very low, which negatively affected the likelihood of distributions to creditors - in 70% of the cases looked at by the researchers, the recoveries were below £10,000 and in 14% they were nothing at all. The report will be used as part of the body of evidence available to keep the corporate insolvency framework under review.

3: Regulatory and Disciplinary Statistics

3.1 Authorisations

A modest downward trend in the overall number of Insolvency Practitioners continues owing to a variety of factors; albeit there has been a slight increase in the volume of appointment taking Insolvency Practitioners.

Table 1: Number of authorised Insolvency Practitioners (2024-2025)      

Year	Category	ICAEW	IPA	ICAS	CAI	Total
2024	IPs at 1 January	740	643	78	47	1508
2024	Appointment takers	606	549	61	41	1257
2025	IPs at 1 January	748	678	77	1	1504
2025	Appointment takers	614	587	63	1	1265

Following CAI’s withdrawal from regulation of Insolvency Practitioners, all 43 practitioners that wished to continue practising made arrangements to transfer to other RPBs as at 1 January 2025. However, a short licence extension was granted to one of 5 retiring Insolvency Practitioners for the purposes of concluding work on a complex case. This licence has since expired.

3.2 Monitoring

Monitoring is an essential part of the role of RPBs as regulators of the insolvency profession. Each RPB has a risk-based monitoring programme in place, the results of which demonstrate the importance of that activity in support of the regulatory objectives.

RPBs undertake routine and targeted visits as part of their monitoring programmes. Targeted visits can happen for several reasons, for example after RPB receives specific information that needs to be investigated or verified, after a routine visit where an order is made by a Committee, or as a result of several complaints about an area of practice.  Rules around targeted visits may vary between individual RPBs.

Data presented in the monitoring tables below relates to visits where all matters were concluded, and outcomes finalised in 2024. It does not include visits that commenced in 2024 but were not complete by the end of the year, nor those that were carried out in 2023 but not finalised by the end of 2024.

When considering figures relating to outcomes, please note that one visit can have more than one outcome (regulatory or disciplinary), each requiring a different follow-up action, and individual outcomes can fall into more than one category.

Table 2: Number of RPB monitoring visits to Insolvency Practitioners carried out in 2024

Visit Type	ICAEW	IPA	ICAS	CAI
Routine	126	221	12	5
Targeted	5	6	2	0

Notes:
ICAS advises that two of their routine visits were in relation to one Insolvency Practitioner, whose corporate and personal insolvency cases were split across two separate visits.

Table 3: Outcomes following routine monitoring visits to Insolvency Practitioners in 2024

	ICAEW	IPA	ICAS	CAI
No further action:
Satisfactory report	72	202	4	3
Follow-up action:
Further visit	6	8	3	0
Ongoing monitoring	19	8	5	0
Regulatory penalties / consent orders	9	20	3	0
Licence impact
Restricted	6	0	0	2
Withdrawn	1	0	0	0
Disciplinary referrals	19	0	3	0
Other	20	227	0	0

Notes:
ICAEW advises that 6 licences were restricted in 2024. Of these, two restrictions were lifted during the year and one was subject to review at year close.

Furthermore, 13 regulatory penalties were ordered by ICAEW in 2024, 9 of which were accepted. The remaining four will be reconsidered in 2025. Appendix A lists 11 regulatory penalties, of which two were offered in 2023 and accepted in 2024.

ICAS advises that all three disciplinary referrals were dismissed following an investigation.

Out of the 227 IPA outcomes categorised as ‘Other’, 224 cases relate to advisory notices, and three cases to warnings.

Advisory notices are issued by the IPA to formally advise insolvency practitioners to improve their behaviour and/or practice within a set timescale. They are typically issued in response to technical breaches that do not meet the threshold for regulatory or disciplinary action. While advisory notices are not published, they are considered as part of IPA’s ongoing risk assessment processes and may influence the frequency of future monitoring.

Table 4: Outcomes following targeted monitoring visits to Insolvency Practitioners in 2024

	ICAEW	IPA	ICAS	CAI
No further action:
Satisfactory report	4	3	1	0
Follow-up action:
Further visit	0	1	0	0
Ongoing monitoring	1	1	1	0
Regulatory penalties	0	1	0	0
Licence impact
Restricted	0	0	0	0
Withdrawn	0	0	0	0
Disciplinary referrals	0	0	0	0
Other	0	3	0	0

Notes:
IPA advises that the three outcomes listed under ‘Other’ relate to advisory notices issued in 2024.
The IPA operates a Volume Provider Regulation (VPR) Scheme  (the Scheme) for high volume providers of Individual Voluntary Arrangements (IVAs) and Protected Trust Deeds (PTDs). Members of the Scheme are subject to a separate focused monitoring regime in addition to IPA’s regular monitoring programme.
A volume provider is defined as an Insolvency Practitioner or an entity which has at any time within the previous 12 months been responsible for the administration of:

• 1,000 or more cases in which one or more person(s) has acted as nominee in relation to an IVA, and/or
• 5,000 or more cases in which one or more person(s) has acted as supervisor in relation to an IVA, and/or
• 2,000 or more cases in which one or more person(s) has acted as trustee in relation to a Trust Deed (in Scotland) whether or not the Trust Deed is protected.

Of the 221 routine visits reported by IPA in 2024, 71 were related to the VPR scheme. No targeted visits were conducted in 2024 in respect of VPR members.

Table 5: Outcomes relating to IPA’s Volume Provider Regulation (VPR) Scheme in 2024

	VPR Scheme
No further action:
Satisfactory report	78
Follow-up action:
Further visit	0
Ongoing monitoring	0
Regulatory penalties / consent orders	5
Licence impact
Restricted	0
Withdrawn	0
Disciplinary referrals	0
Advisory notices	99
Formal warnings	1

3.3 Regulatory and Disciplinary Outcomes

Regulatory and disciplinary action taken by RPBs continues to form a critical part of their work in support of the regulatory objectives.  Whilst representing a small percentage of the profession, the data relating to sanctioning for 2024 demonstrates the important steps taken by the RPBs and their relevant committees.

Similarly to monitoring visits, regulatory and disciplinary action may lead to a number of individual outcomes, each falling into a different category and requiring a different follow-up action.

Table 6: Sanctions during 2024

Category	ICAEW	IPA	ICAS	CAI
Published sanctions	16	46	1	0
Non-published sanctions	1	0	0	0
Licence impact
Suspension/restriction	0	1	0	0
Exclusion/withdrawal	0	0	1	0
Ongoing matters Currently being considered by relevant Investigation or Disciplinary Committees	10	10	1	1

For a list of disciplinary and regulatory sanctions finalised in 2024, please see Annex A at the end of this report.

3.4 Pre-pack Administrations

Monitoring of Statements of Insolvency Practice 16 (SIP 16) disclosure statements in pre-pack administration

SIP 16 sets out what should be included in the Insolvency Practitioner’s disclosure statement issued to all creditors in a pre-pack administration. The statement is a summary of the transaction, and why it was in the best interest of creditors and the best option available. SIPs for England and Wales can be found at www.r3.org.uk/technical-library/england-wales/sips/ and SIPs for Scotland can be found here.

In order to be compliant with SIP 16, the Insolvency Practitioner acting as administrator must send a copy of their SIP 16 statement to all creditors within seven days of the transaction, providing as much detail as possible. The Practitioner must also send a copy to their RPB and include it in the statement of proposals filed at Companies House.

The RPBs are responsible for the monitoring of SIP 16 disclosure statements. IPA and CAI reviewed a sample of statements received during the year as part of a separate SIP 16 monitoring exercise. ICAEW and ICAS have moved away from this method and now conduct SIP 16 monitoring as part of their regular monitoring regime.

Table 7: Monitoring of SIP 16 statements by RPBs during 2024

	ICAEW	IPA	ICAS	CAI
Statements received	298	316	13	1
Statements reviewed	-	76	1	1
Number generally compliant	-	72	1	1
Number deemed non-compliant	-	4	0	0
Of which resulting in regulatory action	-	0	0	0

The volume of SIP 16 statements continues to increase year on year. The RPBs have reported the receipt of (628) statements in 2024, compared to 545 in 2023, 538 in 2022 and 201 in 2021.

Notes:
ICAEW advises that the figure in Table 7 reflects the number of companies for which SIP 16 statements were received, not the number of statements received.

The IPA advises that all identified non-compliance issues relate to late submissions or minor missing information. As all these were considered minor, no regulatory action was taken.

ICAS advises that it moved away from enhanced targeted SIP 16 monitoring on a risk basis following an analysis of the full review of SIP 16 statements received in 2022 and 2023. This decision was taken due to the low number of statements generally received by ICAS and a lack of regulatory concerns around those received. A thematic review may be undertaken in due course to test ongoing compliance.
The table below summarises key information in relation to SIP 16 sales to connected persons. Similarly to the volume of pre-pack administrations, which has increased since 2023, the RPBs report a similar rise in the number of connected person sales (395 in 2024 as compared to 329 in 2023, 201 in 2022 and 106 in 2021).

Table 8: Analysis of pre-pack administrations in respect of connected person sales in 2024

	ICAEW	IPA	ICAS	CAI
Number of connected person sales	179	211	5	0
Number of connected person sales where evaluation has been obtained	178	211	5	0
Number of connected person sales where creditor approval has been sought	1	0	0	0
Evaluator’s opinion regarding reasonableness of grounds and consideration of transaction
Satisfied	178	211	5	0
Not satisfied	0	0	0	0

4: Complaint Statistics

4.1 Insolvency Practitioner Complaints Gateway Statistics

The Complaints Gateway (‘the Gateway’) continues to be the channel for most complaints made against Insolvency Practitioners. In 2024, the Gateway refined its systems to improve the efficiency and robustness of the assessment process in order to deliver a better service. This has resulted in time and resource savings and better measurement of the Gateway’s performance.

During 2024, the Gateway received 656 complaints, a decrease of 13% from 2023. Of these, 144 (22%) were referred to RPBs, 123 (19%) were rejected, 289 (44%) were closed and 100 (15%) were still awaiting further information to reach a decision at the end of 2024.

The Gateway only refers cases that require consideration by the RPB. For each complaint, the Gateway considers whether it falls within the scope for referral to the RPB, based on the information provided on the complaint form along with any supporting evidence. All complainants have the right of appeal for rejected complaints. In 2024, there were 39 appeals, one of which was upheld. The remainder were rejected.

Complaints are closed if the Gateway is unable to contact the complainant or if further information required to assess the complaint has not been provided within a set timeframe. They can also be closed if they do not meet the threshold criteria for assessment, such as the age of the relevant event/conduct, absence of a formal complaint to the Insolvency Practitioner, etc.).

Table 9: Complaints received by the Gateway (2020-2024)

Complaints	2020	2021	2022	2023	2024
Total complaints	782	810	688	750	656
Referred to the RPBs	371	423	212	169	144
Rejected/closed	408	346	364	559	412
Ongoing	3	41	24	22	100

The overall number of referrals has continued to decrease (when considering the figures below, please note that the data for 2021 includes 94 individual complaints about one case referred to ICAEW).

Table 10: Number of referrals made to RPBs

	2020	2021	2022	2023	2024	% in 2024
IPA	222	169	124	92	99	69%
ICAEW	133	234	89	63	43	36%
ICAS	12	15	6	12	9	6%
CAI	1	3	1	1	0	0%
Total	368	423	220	168	144	100%

IVAs and liquidations remain the most common insolvency procedures the Gateway deals with and refers to the relevant RPB, followed by administrations. Overall, the most significant change in referral numbers was in relation to IVA-related complaints, which increased by 11% as compared to 2023 figures.

Table 11: Referrals by insolvency procedure

Insolvency Type		2024	% in 2024	% in 2023
Individual voluntary arrangement (IVA)		58	40%	29%
Liquidation		54	38%	42%
Administration		14	10%	16%
Bankruptcy		9	6%	8%
Trust Deed		5	3%	2%
Sequestration		4	3%	1%
Company voluntary arrangement (CVA)		0	0%	1%
Other		0	0%	1%
Total		144	100%	100%

The top three reasons for complaints that are referred to the RPBs remain unchanged: communication breakdown, and competence and due care, followed by SIP 3. However, where there was a slight rise in complaints referred that related to competence and due care and SIP 3, compared to 2023.  There was a marked decrease in the number of referrals related to communication breakdown, which went down by 13%.

Table 12: Referrals by subject matter

	2024	% in 2024	% in 2023
Communication breakdown	43	30%	43%
Competence and due care	29	20%	18%
SIP 3 (Individual and Company Voluntary Arrangements)	24	17%	14%
SIP 1 (Fundamental Principles)	15	10%	3%
Behaviour	14	10%	11%
Other	7	5%	17%
Fees	4	3%	-
SIP 2 (Investigations by Office Holders)	2	1%	-
Dealing with assets	2	1%	1%
Integrity	2	1%	-
Conflict of interest	1	1%	1%
Intelligence	1	1%	1%
Total	144	100%	100%

There has been little change when looking at the top two sources of complaints: debtors, and creditors. However, the two categories effectively swapped places from 2023 to 2024, with complaints from debtors increasing by 10%.

Table 13: Gateway complaint referrals by complaint source

	2024	% in 2024	% in 2023
Debtor	51	35%	25%
Creditor	43	30%	31%
Director	18	13%	8%
Insolvency Practitioner	13	9%	3%
Other	6	4%	24%
Debtor’s friend/family	4	3%	4%
Shareholder	3	2%	1%
Debt advisor	2	1%	3%
Employee	2	1%	1%
Total	144	100%	100%

The number of complaint rejections reduced in 2024: 123 as compared to 169 in 2023. The number of complaints about various effects of insolvency, which is the top reason for rejecting a complaint, dropped by 30%. Rejections classed as “Other” include a variety of reasons, including a lack of or insufficient evidence, matters outside the Gateway’s remit, or matters not meeting the regulatory bar set by the RPBs.

Table 14: Reasons for rejection of Gateway complaints

	2024	% in 2024	% in 2023
Effect of insolvency	46	37%	64%
Other	45	37%	4%
Commercial matter	26	21%	17%
Conduct over three years	4	3%	8%
Director’s conduct	1	1%	4%
Actions of third party	1	1%	3%
Total	123	100%	100%

The Gateway saw a reversal of the previous trend of closure numbers going up year on year. In 2024, there were 289 closures as compared to previous few years which saw 390 in 2023, 364 in 2022, and 272 in 2021. The top reason for closure has not changed: no response to a request for more information, but in 2024 it made up over 70% of all closures (205 out of 289), whereas in 2023 it was 57% (224 out of 390).

Table 15: Reasons for closure of Gateway complaints

	2024	% in 2024	% in 2023
No response to request for evidence/ information	205	71%	57%
Complaint not about an IP	25	9%	7%
Complaint withdrawn	17	6%	4%
Other	16	6%	1%
Asked to complain to IP first	16	6%	27%
Already been through the complaint process	10	3%	4%
Total	289	100%	100%

4.2 Complaints - RPB statistics

RPBs can open complaints based on referrals from internal committees, press coverage, direct complaints or intelligence from the Insolvency Service or other sources.

Table 16: Complaints received by RPBs from sources other than Gateway

Complaints	ICAEW	IPA	ICAS	CAI
Carried over from 2023	69	35	2	1
Total complaints opened	59	46	5	0
Rejected/closed	61	31	7	0
Ongoing	67	50	0	1

Table 17 shows how many complaints over 12 months old remained open with each RPB as of 31 December 2024, ordered by the year they were opened.

These complaints are often complex. Each RPB provides this information to the Insolvency Service quarterly for progress to be monitored and, when appropriate, challenged.

Table 17: Complaints made to RPBs remaining open over 12 months

RPB	Total		2018	2019	2020	2021	2022	2023
ICAEW	44		0	1	2	4	11	26
IPA	21		1	1	1	0	6	12
ICAS	1		0	0	0	0	0	1
CAI	0		0	0	0	0	0	0

For comparison, the relevant totals in the 2023 Annual Review were as follows: 47 for ICAEW, 19 for IPA, 3 for ICAS and 1 for CAI.

4.3 Complaints about RPBs

As oversight regulator, the Insolvency Service receives complaints about the RPBs and the way in which they carry out their regulatory functions when considering complaints. During an investigation, a consideration is given to whether (or not) the relevant RPB has complied with its own relevant procedures and regulatory objectives. If considered appropriate, recommendations may be made for potential changes to process, training or other important lessons to be learned.

In 2024, the Insolvency Service considered only two such complaints. Neither of them was upheld and no recommendations were deemed necessary.

Table 18: Complaints received about RPBs

Complaints	ICAEW	IPA	ICAS	CAI
Received	0	0	2	0
Upheld	0	0	0	0
Partially upheld	0	0	0	0
Rejected	0	0	2	0
Closed/withdrawn	0	0	0	0
Ongoing	0	0	0	0

Annex A

Summary of regulatory and disciplinary sanctions issued in 2024

A detailed explanation of the Fundamental Principles referred to in the table below is provided in the Insolvency Practitioner’s Code of Ethics.

Sanctions are usually publicised but in exceptional circumstances, a decision may be made by the relevant Committee not to publish or to anonymise the details of a sanction.

Further details of individual sanctions can be found on the RPB’s websites:
ICAEW Disciplinary Database
IPA Enforcement Notices
ICAS Disciplinary Notices
CAI Register of Regulatory Findings and Orders
The list below is arranged by the type of sanction, then alphabetically by the RPB, and then alphabetically by the name of the Insolvency Practitioner.

Exclusions and withdrawals/revocations of licence

RPB	IP	Sanction	Reason
ICAEW	Matthew Fox	Licence withdrawal	Under Regulation 5.12d of the Insolvency Licensing Regulations and Guidance Notes with effect from 20 September 2024, due to significant statutory filing deficiencies on his portfolio.
ICAS	Kevin McLeod	Exclusion from membership £8,470 costs	A breach of the Fundamental Principles of Professional Competence and Due Care and Professional Behaviour, and the ICAS Insolvency Regulations, where: a. the IP as liquidator failed to put in place appropriate financial controls and safeguards in breach of Statement of Insolvency Practice (SIP) 11. b. as trustee, he failed to properly and timeously renew an inhibition to protect the estate’s interest in the heritable estate. c. as trustee in sequestration, failed to properly recover, manage and realise the debtor’s estate. d. as sole director of insolvency practice, failed to submit to Companies House statutory accounts for four accounting periods.

Severe reprimand

RPB	IP	Sanction	Reason
ICAEW	Lauren Auburn	Severe reprimand £10,000 fine £5,440 costs	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP failed to comply with the requirements of SIP 16 in one administration.
ICAEW	Kelly Burton	Severe reprimand £18,000 fine £9,070 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, in respect of one administration appointment: a) failed to identify property holding costs and whether a funding line was required, and agreed contracts for services without having secured funds to pay, and b) failed to produce and maintain records in relation to the above.
ICAEW	Jonathan Gribble	Severe reprimand £15,000 fine £6,985 costs	A breach of the Fundamental Principle of Objectivity when the IP referred 266 individuals to IVA providers, in breach of the permitted exclusion under the Financial Services and Markets Act 2000 by providing debt counselling services when not in reasonable contemplation of an insolvency appointments.
ICAEW	Siann Huntley	Severe reprimand £3,000 fine £4,255 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, as liquidator failed to produce and maintain any or sufficient written records in respect of: a) a deposit due from the company, and b) when the deposit was not paid, the decision to void the CVA.
ICAEW	Zafar Iqbal	Severe reprimand £25,000 fine £25,000 costs	A breach of the Fundamental Principles of Professional Competence and Due Care, and Professional Behaviour, when the IP, as administrator: a) failed to take reasonable steps to obtain appropriate knowledge and understanding of the company and its assets, and b) failed to create any or sufficient written records in considering the threats to the fundamental principles, and c) and sold the Company assets to a connected party without valuation or adequate marketing process. As administrator to another company, failed to a) undertake adequate investigation and secure the books and records in breach of SIP 2, and b) progress the liquidation in a diligent manner, completed a sale of the goodwill to a connected party without valuation, and c) comply with statutory filing requirements.
ICAEW	Stuart Kelly	Severe reprimand £8,750 fine £12,700 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, as Trustee in bankruptcy, engaged Solicitors and failed to ensure that the work required solicitors’ assistance, that the costs incurred were fair and reasonable, and that he retained sufficient control over the work.
ICAEW	Amy Mehers	Severe reprimand £4,250 fine £3,985 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, as Liquidator, failed to investigate the Company’s assets and/or progress the liquidation in a timely manner.
ICAEW	Jamie Playford	Severe reprimand £5,000 fine £6,595 costs	A breach of the Fundamental Principle of Professional Competence and Due Care in respect of five MVL appointments, when the IP failed to undertake adequate due diligence to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017.
ICAEW	Jamie Playford	Severe reprimand £5,000 fine £5,485 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, in respect of four CVLs, failed to ensure that the Statement of Affairs complied with Rule 6.4 of the Insolvency Rules 2016.
ICAEW	Mark Prideaux	Severe reprimand 14,000 fine £8,525 costs	A breach of SIP 3.1 in respect of six IVAs, when the IP failed to a) provide creditors with sufficient evidence to make an informed decision, and b) ensure debtors received appropriate advice, and c) disclose sufficient information to identify the source of the IVA referrals and any payments made. A breach of SIP 9, when the IP failed to provide creditors with information to allow them to form an understanding of the costs and expenses of each IVA.
ICAEW	Mark Prideaux	Severe reprimand £13,500 fine £7,135 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, in one IVA, failed to deal with a change of financial circumstances properly and in a timely manner. In one IVA the IP failed to provide creditors with information to allow them to form an understanding of the costs and expenses of the IVA in breach of SIP 3.1 and SIP 9.
ICAEW	Mark Prideaux	Severe reprimand £500 fine no costs	A breach of the Fundamental Principle of Professional Competence and Due Care, and SIP 3.1 in respect of one IVA, when the IP: a) failed to take action following a breach, b) failed to record the vote of a creditor, which led to a failure to make the dividend, and c) failed to respond to correspondence and a complaint in a timely manner.
IPA	Gary Bell	Severe reprimand x2 £12,500 fine £1,500 costs	1. A breach of Section 330 of the Proceeds of Crime Act 2002 (‘POCA02’) when the IP, acting in contemplation of appointment as Liquidator, and as Liquidator, failed to report the misapplication of funds obtained from a Coronavirus Business Interruption Loan to his firm’s Money Laundering Reporting Officer (‘MLRO’). 2. A breach of the Fundamental Principle of Professional Competence and Due Care and/or SIP 2, when the IP, as Liquidator of two companies: a) failed to conduct adequate investigations into the affairs of the companies and its directors; and b) failed to adequately document the scope of investigations carried out and the conclusions reached.
IPA	Jeremy Bennett	Severe reprimand £5,000 fine £1,250 costs	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when in the period 2021-2022, the IP as office holder of multiple companies, failed to file in a timely manner, or at all, no less than 18 progress reports at Companies House.
IPA	Adam Boys	Severe reprimand £10,000 fine £3,988 costs	A breach of the Fundamental Principle of Professional Behaviour when the IP continued to advertise services that he was unable to offer, despite reminders from the Secretariat not to do so.
IPA	Adam Boys	Severe reprimand £6,000 fine £450 costs	A breach of the Fundamental Principle of Professional Competence and Due Care and a failure to comply with SIP 3.1 when, between May and July 2022, in the course of advising and obtaining instructions from debtors, the IP failed to give proper advice resulting in a debtor being placed into an IVA that was unsuitable and unviable.
IPA	Christopher Brooksbank	Severe reprimand £2,000 fine £2,012 costs	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP failed to file no less than 57 progress reports at Companies House.
IPA	Alan Cadman	Severe reprimand £4,000 fine £2,540 costs	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP failed, as liquidator: a) to ensure that Forms RP15 and RP15A were submitted in a timely manner in respect of one company; and b) to make a distribution to preferential creditors in a timely manner in respect of two companies.
IPA	Ian Goodhew	Severe reprimand £7,500 fine £6,792 costs	A breach of the Fundamental Principle of Professional Behaviour, when the IP, as Trustee in bankruptcy, engaged the services of a third party that was not fit to address the needs of the recipient of the service.
IPA	Martin Halligan	Severe reprimand £5,000 fine £450 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, as office holder of multiple companies, failed to file Progress Reports at Companies House, in a timely manner or at all.
IPA	Richard Hunt	Severe reprimand £7,500 fine £375 costs	A breach of Rule 340.4 of the Insolvency Code of Ethics by operating a referral program whereby clients were offered a financial incentive for the introduction of potential clients who were considered eligible for business asset disposal relief.
IPA	David Kerr	Severe reprimand £5,000 fine £375 costs	A breach of Rule 340.4 of the Insolvency Code of Ethics by virtue of the IP’s association with a referral program whereby clients were offered a financial incentive for the introduction of potential clients who were considered eligible for business asset disposal relief.
IPA	Gareth Latimer	Severe reprimand £5,000 fine £1,875 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when, on no less than 11 cases, the IP failed to clearly differentiate and segregate estate money, client money and money belonging to the entity in which he was working contrary to paragraph 3 of SIP 11.
IPA	Hemal Mistry	Severe reprimand £5,000 fine £600 costs	A breach of Regulation 30 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (‘MLR’) 2017 (as amended), when the IP failed to undertake Customer Due Diligence prior to the establishment of the business relationship, and prior to the acceptance of funds, in two liquidation estates.
IPA	Maubhai Mistry	Severe reprimand £6,500 fine £600 costs	A breach of Regulation 30 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (‘MLR’) 2017 (as amended), when the IP failed to undertake Customer Due Diligence prior to the establishment of the business relationship, and prior to the acceptance of funds, in two liquidation estates.
IPA	Wayne Macpherson	Severe reprimand x3 £20,000 fine £7,708 costs	1. A breach of the Fundamental Principle of Professional Competence and Due Care and section 330 of POCA02 when the IP failed to report Suspicious Activity to his MLRO. 2. A breach of the Fundamental Principle of Professional Competence and Due Care when the IP failed correctly to understand and apply: (a) the circumstances which he is obliged to report to his firm’s MLRO; and (b) the turnover qualification governing the amount which a company is allowed to borrow under the Government’s Bounce Back Loan Scheme. 3. A breach of the Fundamental Principle of Professional Competence and Due Care and/or Section 7A Company Directors Disqualification Act 1986 by: (a) submitting to the Director Conduct Reporting Service (DCRS) a report which was materially misleading, and (b) failing to update timeously the DCRS when further material evidence came to his knowledge. 4. A breach of the Fundamental Principle of Professional Competence and Due Care when the IP breached SIP 2 by failing to conduct timeous and appropriate investigations into the affairs of the company and its director.
IPA	Nigel Price	Severe reprimand £2,000 fine £450 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP: 1. failed in no less than 9 cases to prepare and/or deliver a copy of the progress report to the Registrar of Companies, and 2. failed in no less than 32 cases to deliver a copy of 41 annual progress reports to the Registrar of Companies within the two-month period defined by Rule 18.7 (6).
IPA	Dylan Quail and Ian Millington	Severe reprimand £7,500 fine £450 costs	A breach of SIP 3.1 when the IPs, in their role as Joint Supervisors of three IVAs, failed (prior to seeking a variation to the terms of the IVAs) to carry out Income and Expenditure reviews to check the affordability and sustainability of the IVA.
IPA	David Rankin	Severe reprimand £7,500 fine £1,383 costs	A breach of R340.4 of the Insolvency Code of Ethics when, between 27 April 2021 and 31 December 2022, the IP operated a referral program whereby existing clients were offered an incentive for the introduction of potential clients which subsequently led to the IPs’ appointment as nominee of 115 IVAs.
IPA	Rina Rohilla	Severe reprimand x3 £15,000 fine £450 costs	1. A breach of the Fundamental principle of Professional Competence and Due Care, when the IP, as Office Holder of several insolvency estates: a) failed to complete statutory filings in a timely manner; b) provided inaccurate information to creditors on four cases; c) failed to competently deal with an Administration Estate; d) failed in all cases to comply with the provisions of SIPs 7 and 11; e) failed to assess insurance risks when she allowed the insurance on a property in a bankruptcy estate to expire. 2. A breach of the Fundamental Principle of Competence and Due Care and SIP 2, when the IP failed to conduct and record timely and appropriate investigations into the affairs of the companies and their directors, on no less than four companies. 3. Breached the Money Laundering and Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (‘MLR’) 2017, when the IP, as proposed Office Holder and Office Holder of two companies, failed to: a) complete adequate Customer Due Diligence prior to the establishment of a business relationship, b) adequately assess the level of risk, c) conduct ongoing monitoring of the business relationship.
IPA	Mark Sands	Severe reprimand £6,000 fine £4,924.50 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP, as Nominee of a proposed IVA, failed to properly verify the debtor’s assets and liabilities to ensure that the IVA proposal had a reasonable prospect of being approved and successfully implemented.
IPA	Alan Simon	Severe reprimand £6,500 fine £750 costs	A breach of Section 330 of the POCA02, when the IP, acting in contemplation of his appointment as Liquidator: a) failed to report his suspicion of criminal conduct to the MLRO at his first firm; and b) failed to report his suspicion of criminal conduct to the MLRO at a successor firm.
IPA	Dean Smith	Severe reprimand x2 £9,000 fine £450 costs	1. A breach of the Fundamental Principle of Professional Competence and Due Care and/or SIP 2, when the IP, as Liquidator of no less than eight companies, failed to conduct appropriate investigations into the affairs of the company and/or its directors. 2. A breach of Section 331 of POCA02 when the IP, in his role as Liquidator of various companies, failed to report a suspicion of criminal conduct.
IPA	Laura Stewart	Severe reprimand £4,000 fine £1,200 costs	A breach of SIP 11 when the IP failed to hold estate money in account(s) where the funds are readily identifiable to that estate.
IPA	Daniel Taylor	Severe reprimand x2 £11,000 fine £1,450 costs	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP: 1. as liquidator of a) one company, failed to conduct adequate investigations into the affairs of the company as required by SIP 2; b) five companies, failed to ensure that the scope of his investigations and the conclusions reached were adequately documented as required by SIP 2 and Regulation 13 of The Insolvency Practitioners (Amendment) Regulations 2015. 2. acting in contemplation of appointment as Liquidator and/or as Liquidator of two companies, breached Section 330 of the POCA02 when, having reasonable grounds for knowing or suspecting criminal conduct, he failed to make the required disclosures to his firm’s Money Laundering Reporting Officer, either at all or as soon as was practicable.
IPA	Katy Walker	Severe reprimand £7,500 fine £1,383.75 costs	A breach of R340.4 of the Insolvency Code of Ethics when, between 27 April 2021 and 31 December 2022, the IP operated a referral program whereby existing clients were offered an incentive for the introduction of potential clients which subsequently led to the IP’s appointment as nominee of 115 IVAs.
IPA	Samantha Warburton	Severe reprimand £5,000 fine £6,562.50 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP: 1. did not have sufficient monitoring and controls in place to identify, at an early stage, that dividends were paid to a duplicate creditor, and 2. did not repay funds into the IVA that were paid to the duplicate creditor in error, for a period of over 11 months.
IPA	Tracy Whittaker	Severe reprimand £5,000 fine £1,125 costs	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP and staff for whom she was responsible: 1. failed to advise creditors that debtor had increased his full and final settlement offer, and 2. wrongly implied that the debtor’s increased offer had been put to creditors and rejected.
IPA	Tracy Whittaker	Severe reprimand £5,000 fine £1,962.50	A breach of the Fundamental Principle of Professional Competence and Due Care when, between November 2021 and January 2023, as Supervisor of an IVA, the IP 1. failed to progress the case to closure; and 2. failed to respond to the debtor’s numerous requests for an update on the status of her IVA.
IPA	Anonymised	Severe reprimand £5,000 fine £900 costs	1. A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP, as office holder of various companies: a) failed to declare and pay dividends when funds permitted; and b) failed to progress a liquidation in a timely manner; and c) breached SIP 3.2 when he failed to take prompt action following departure from the terms of a CVA, and obtain a variation to the length of the CVA before purportedly being implemented; and d) failed to prepare and/or file annual progress reports at Companies House, and e) failed in no less than 39 cases to file 82 annual progress reports in a timely manner. 2. A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP, as Trustee of bankruptcy: a) failed to advertise a notice of intention to declare a dividend in the gazette; and/or b) failed to pay a pari passu dividend to all proven creditors. 3. A breach of the Fundamental Principle of Integrity when the IP submitted a signed licence renewal form confirming that the required 50 hours of Continuing Professional Development (CPD) had been completed for the previous two years when only 13 hours were completed. 4. A breach of the Fundamental Principle of Professional Competence and Due Care and of the Money Laundering, Terrorist Financing and Transfer Funds (Information on the Payer) Regulations 2017 when the IP failed to carry out due diligence and verify the identity of the entity paying his fees on at least four companies.
IPA	Anonymised	Severe reprimand x2 £15,500 fine £15,000 costs	1. As liquidator of a company, when discussing settlement of the costs of the company’s former liquidator, the IP failed to inform him: (a) that he had drawn a substantial sum in respect of his own fees, and/or (b) that he had agreed with an adviser that no fees would be paid to the former liquidator and/or that the IP would be allowed to take fees on the understanding that the former liquidator would not be entitled to take his fees, in breach of the Fundamental Principles of Transparency, Integrity and Professional Behaviour. 2. A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP: (a) failed to pay an amount payable to the former liquidator, a person employed or authorised to assist in the preparation of a statement of affairs or of accounts, and/or (b) paid out of assets of the company his own remuneration in priority to an amount payable to the former liquidator, a person employed or authorised to assist in the preparation of a statement of affairs or of accounts.

Reprimands

RPB	IP	Sanction	Reason
ICAEW	Amy Mehers	Reprimand £5,000 fine £7,210 costs	A breach of the Fundamental Principle of Professional Behaviour and Professional Competence and Due Care when the IP as Trustee, failed to take reasonable care to clarify whether an amount paid to a secured creditor constituted a full and final settlement of security, and failed to take appropriate steps to deal with the remaining assets to the detriment of the secured creditor.
ICAEW	Nicholas Myers	Reprimand £2,200 fine £3,400 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP breached statutory requirements in relation to: a) an extension of one administration, and b) the end of one administration, and c) reappointment to the same company, and d) and issuing of his proposals.
IPA	Jeremy Bennett	Reprimand £1,500 fine £450 costs	A breach of SIP 2 when the IP, as Liquidator, failed: a) to carry out an appropriate initial assessment of matters that may lead to recoveries, and b) to determine the extent of the investigation in the circumstances of the case, and c) to properly document the initial assessments, investigations, and conclusions.
IPA	Adam Boys	Reprimand £2,000 fine £450 costs	A breach of the terms of two IVAs when the IP drew disbursements for which he did not have the requisite approval.
IPA	Daniel Leigh	Reprimand £6,000 fine £450 costs	A breach of Section 331 of the POCA02, when the IP, as Liquidator of two companies in Creditors Voluntary Liquidation (CVL), failed to report his suspicion of criminal conduct to the National Crime Agency.
IPA	Katherine Merry and Ben Dyer	Reprimand £2,000 fine £3,045 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IPs, as joint liquidators, failed to: a) address correspondence from the company’s pensions administrator in a timely manner; b) ensure that complete and accurate Forms RP15 and RP15A were submitted to the Redundancy Payments Service (RPS) prior to the closure of the case; and c) failed to address queries raised by the RPS in a timely manner.
IPA	Clive Morris	Reprimand £2,000 fine £4,005 costs	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP failed to: a) communicate with the company’s pensions administrator in a timely manner; and b) ensure that complete and accurate Forms RP15 and RP15A were submitted to the RPS in a timely manner and prior to leaving office.
IPA	Paul Palmer	Reprimand £2,000 fine £5,100 costs	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP failed to: a) ensure that complete and accurate Forms RP15 and RP15A were submitted to the RPS in a timely manner; and b) address correspondence from the company’s pensions administrator in a timely manner.
IPA	Laura Prescott	Reprimand £3,000 fine £4,200 costs	A breach of the Fundamental principle of Professional Competence and Due Care when the IP, as Supervisor of an IVA: a) failed to respond to the debtor’s payment proposal dated 26 June 2022 to clear arrears that had accrued from December 2021; and b) failed to acknowledge and/or allocate correctly the contributions made by the debtor in line with her own payment proposal from July 2022 to November 2022.
IPA	David Rankin	Reprimand £5,000 fine £5,925 costs	A breach of the Fundamental Principles of Professional Competence and Due Care and Professional Behaviour when the IP (and/or his staff), as advisor and/or nominee of 11 IVAs: a) failed, in ten cases, to provide the debtor, one of whom was vulnerable, with appropriate advice when he and/or his staff provided the debtor with misleading and/or factually incorrect information. b) failed, in two cases, to provide the debtor, one of whom was vulnerable, with appropriate advice when he and or his staff misled the debtor by not correcting a factually incorrect comment that the debtor had made. c) in five cases, made inappropriate comments to the debtor, one of whom was vulnerable.
IPA	Mike Reeves	Reprimand £1,500 fine £450 costs	A breach of the Fundamental Principle of Professional Behaviour when the IP entered into an agreement with another Insolvency Practitioner for an ‘information gathering pack’, when he knew that the Insolvency Practitioner was undertaking a regulated activity without authorisation (by providing advice to the debtor when he was not in reasonable contemplation of his own appointment).
IPA	Dominik Thiel-Czerwinke	Reprimand £6,500 fine £4,162.50 costs	A breach of the Fundamental Principles of Professional Competence and Due Care and Professional Behaviour, when as liquidator of a company the IP: 1. failed to respond to the pension scheme administrator on nine separate occasions regarding submission of outstanding RP15 and RP15A forms, and 2. closed the liquidation estate without submitting the forms, in breach of s125(3) of the Pension Schemes Act.
IPA	Samantha Warburton	Reprimand £1,500 fine £4,200 costs	A breach of the Fundamental Principle of Professional Competence and Due Care and Professional Behaviour by failing to respond, in a timely manner or at all, to numerous requests for information, from the debtor and the debtor’s solicitor, relating to the terms of and information contained in the debtor’s Protected Trust Deed.

Other disciplinary penalties

RPB	IP	Sanction	Reason
IPA	IPA members x2	Warning	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IPs: 1. failed to obtain the required consent from the secured creditors to extend the administration at the first anniversary, 2. incorrectly allocated Counsel’s fees as being drawn from the Administration estate and failed to recognise this error prior to the administration’s closure, 3. failed to prepare and issue a progress report for the correct period. 4. issued a final report to creditors that failed to comply with the Insolvency Rules and SIP by: a) failing to include information relevant to creditors, including key information regarding the VAT position and details of the trading account. b) failing to correctly split the expenses in the final report.
IPA	IPA member	Warning	A breach of The Money Laundering and Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, when the IP, in respect of two cases, failed to: a) verify the identity of the customer prior to the establishment of a business relations, and b) maintain case specific evidence of the level of risk on one of those.
IPA	IPA member	Warning	A breach of the Fundamental Principle of Professional Competence and Due Care and Professional Behaviour when the IP, as the sole insolvency practitioner and a director of an insolvency practice, did not have sufficient procedures in place to satisfy himself that any advertising or other form of promotional activity complied with relevant codes of practice in relation to marketing.
IPA	IPA member	Warning	A breach of the Fundamental Principle of Professional Competence and Due Care when the IP put forward a variation proposal to creditors without properly verifying the debtor’s income and expenditure.
IPA	IPA member	Warning	A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP, as Supervisor of an IVA: (a) failed to conclude the debtor’s IVA in a timely manner; and (b) failed to respond adequately to the debtor’s emails requesting an update about the closure of her IVA.

Regulatory penalties

RPB	IP	Sanction	Reason
ICAEW	Dorothy Brown	Regulatory penalty of £1,500	A failure to verify claims for outstanding holiday pay for employees on Forms RP14A, without informing the RPS that a verification has not been carried out.
ICAEW	Adam Buck	Regulatory penalty of £1,000	A failure to notify the RPS that the employee claims on an administration and a liquidation were based on information provided by the directors.
ICAEW	Adele Firestone	Regulatory penalty of £500	Drawing £6,744 of unapproved remuneration on a compulsory liquidation.
ICAEW	Paul George	Regulatory penalty of £500	A failure to undertake a compliance review in 2022 in accordance with Regulation 3.13 of the Insolvency Licensing Regulations and Guidance Notes.
ICAEW	Steven Henson	Regulatory penalty of £1,000	A failure to notify the RPS that the employee claims on an administration and a liquidation were based on information provided by the directors.
ICAEW	Scott Kippax	Regulatory penalty of £3,000	A failure to pay dividends on a CVL in a timely manner.
ICAEW	Yiannis Koumettou	Regulatory penalty of £10,000	A 12-month delay in paying a preferential dividend to employees in a CVL, and a failure to notify the RPS that the directors’ claims had not been verified on a CVL where no claims were made by the directors.
ICAEW	Finbarr O’Connell	Regulatory penalty of £1,500	In relation to an unjustified delay in paying a dividend on a CVL.
ICAEW	Gerard Ratcliffe	Regulatory penalty of £5,000	A failure to comply with the Fundamental Principle of Professional Behaviour for breaching the restriction on his insolvency licence.
ICAEW	Catherine Varney	Regulatory penalty of £5,000	A failure to segregate individual estate funds within the banking system in accordance with SIP 11.
ICAS	Laurence Factor	£7,500 penalty	1. A breach of SIP 11, when the IP failed to hold estate funds in individual estate accounts. 2. A breach of the Fundamental Principle of Professional Competence and Due Care when the IP failed to investigate the validity and potential misuse of a Bounce Back Loan.
ICAS	Penny McCoull	£3,500 penalty	A breach of the Fundamental Principle of Professional Competence and Due Care on grounds of: 1. a failure to take appropriate steps to verify the information provided by a claims management company before submitting claims to the Redundancy Payments Office. 2. In two appointments, insufficient evidence of (a) appropriate action to recover books and records from directors, (b) a proper investigation of Covid-related loans, and (c) a reasonable level of work and consideration on the files (contrary to the principles in SIP 2). 3. Drawing of pre-appointment fees in four CVLs without the necessary approval from creditors. 4. Unsatisfactory delays in the payment of a dividend to creditors in one case, with a lack of progress reports.
ICAS	Michael Reid	£11,500 penalty	1. A breach of SIP 9, when the IP failed to maintain adequate and compliant time records. 2. A breach of the Fundamental Principle of Professional Competence and Due Care, when the IP failed to review or verify employee claims against payroll or other appropriate documentation, and to notify the RPS that claims were not verified. 3. A breach of SIP 2 and the Insolvency Act when the IP failed to document investigation work to support conclusions reached, including investigations into the validity and potential misuse of a Bounce Bank Loan.