FINAL NOTICE

1.
For the reasons set out in this Final Notice, the Authority hereby takes the following
action against PLSL.

2.
The Authority issued to PLSL the Decision Notice which notified it that for the
reasons given below and pursuant to section 55J of the Act, the Authority had
decided to cancel PLSL’s permission.

3.
PLSL has not referred the matter to the Tribunal within 28 days of the date on
which the Decision Notice was issued to it.

4.
Accordingly, the Authority has today cancelled PLSL’s permission.

DEFINITIONS

5.
The definitions below are used in this Final Notice:

“the Act” means the Financial Services and Markets Act 2000;

“the Authority” means the Financial Conduct Authority;

“the Decision Notice” means the Decision Notice issued to PLSL dated 26 March
2019;

“PLSL” means Philips Legal Solutions Limited;

“PLSL’s Part 4A permission” means the permission granted by the Authority to PLSL
pursuant to Part 4A of the Act;

“the Returns” means the CCR-Complaints, CCR001 (Financial Data) and CCR002
(Volumes) returns for the period ended 31 March 2018, which PLSL was due to
submit to the Authority by 15 May 2018;

“the suitability Threshold Condition” means the threshold condition stated at
parapgraph 2E of Schedule 6 to the Act;

“the Threshold Conditions” means the threshold conditions set out in Schedule 6 to
the Act;

“the Tribunal” means the Upper Tribunal (Tax and Chancery Chamber); and

“the Warning Notice” means the Warning Notice issued to PLSL dated 5 March 2019.

REASONS FOR ACTION

6.
On the basis of the facts and matters and conclusions described in the Warning
Notice issued to PLSL and in the Decision Notice, it appears to the Authority that
PLSL is failing to satisfy the suitability Threshold Condition, in that the Authority is
not satisfied that PLSL is a fit and proper person having regard to all the
circumstances, including whether PLSL managed its business in such a way as to
ensure that its affairs were conducted in a sound and prudent manner.

7.
This is because PLSL has failed to comply with the regulatory requirement to submit
the Returns. PLSL has not been open and co-operative in all its dealings with the
Authority, in that it has failed to respond adequately to the Authority's repeated
requests for it to submit the Returns, and has thereby failed to comply with Principle
11 of the Authority's Principles for Businesses and to satisfy the Authority that it is
ready, willing and organised to comply with the requirements and standards of the
regulatory system.

8.
These failures, which are significant in the context of PLSL’s suitability, lead the
Authority to conclude that PLSL has failed to manage its business in such a way as
to ensure that its affairs are conducted in a sound and prudent manner, that it is
not a fit and proper person, and that it is therefore failing to satisfy the Threshold
Conditions in relation to the regulated activities for which PLSL has had a
permission.

DECISION MAKER

9.
The decision which gave rise to the obligation to give this Final Notice was made
by the Regulatory Decisions Committee.

IMPORTANT

10.
This Final Notice is given to PLSL in accordance with section 390(1) of the Act.

Publicity

11.
The Authority must publish such information about the matter to which this Final
Notice relates as the Authority considers appropriate. The information may be

published in such manner as the Authority considers appropriate. However, the
Authority may not publish information if such publication would, in the opinion of
the Authority, be unfair to PLSL or prejudicial to the interest of consumers.

12.
The Authority intends to publish such information about the matter to which this
Final Notice relates as it considers appropriate.

Authority Contact

13.
For more information concerning this matter generally, please contact Rachel
Fasanya at the Authority (direct line: 020 7066 3202).

Anna Couzens
Enforcement and Market Oversight Division