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He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

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Numbers have remained steady a year on, and in H1 this year, various markets were hailed as core growth drivers for the business, including Australia, New Zealand, Spain and the UK.

Meanwhile, cost-saving efforts have seen retail shops and operational roles cut this year. And the group has chosen to exit its CEE business and sell off a significant share.

In August newly appointed CFO Michael Snape said the move was expected to de-lever, unlock and return capital to shareholders.

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