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Sole practitioner excluded after widespread gross negligence

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A sole practitioner has been excluded from the ICAEW after a practice assurance visit discovered “widespread and egregious” AML and accounts production failings and that he was effectively using his personal bank account as his office account.

24th Jan 2022
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An ICAEW disciplinary tribunal heard how Paul Dyer, an ICAEW member since1969 and owner of the accountancy firm P G Dyer, failed to follow anti-money laundering (AML) policies, demonstrated a lack of knowledge of generally accepted accounting principle (GAAP) and that his failings were “tantamount to gross negligence”.

In one of the eye-catching complaints held against him, Dyer received a total of £267,083 of client money into his personal account over a five year period, and he didn’t immediately pay this money into a client’s bank account. 

The sole practitioner admitted all five complaints, including failures in client money handling, in carrying out customer due diligence and risk assessments on all clients and in complying with GAAP.  

The tribunal considered withdrawing Dyer’s practising certificate, without expelling him from membership, but such was the severity of the complaints dating back to 2011, that the tribunal concluded that “any order which allowed Mr Dyer to retain his membership would damage the reputation of the profession and would not be adequate to protect the public”.

The tribunal excluded Dyer from the ICAEW and ordered him to pay costs of £12,316. 

Client money handling complaint

Dyer was first pulled up on client money regulation and money laundering regulation (MLR) failures as part of a practice assurance visit in May 2016. 

By the time of the follow-up visit in November 2017, the quality assurance department (QAD) found that Dyer had only partially addressed the issues raised, such as stopping the handling of client money, but he still did not have AML procedures in place nor was he able to show that he could produce GAAP compliant accounts. 

The lack of client money handling procedures was one of the biggest concerns coming out of the original visit. The investigation committee later reported that Dyer was retaining money due to his clients in his own bank account and he did this on 126 occasions over a five year period until October 2016. 

Dyer had argued that he had an understanding with his clients that when he received a tax refund on their behalf he could deduct his fees from it. While the refunds were not of significant funds, the investigation committee found that he was not keeping adequate records of the amount paid. 

Furthermore, the investigation committee found that the money was not paid immediately or as soon as he was aware that the funds had been received. 

Another concern was that two sums of client money in excess of £10,000 was held in this account for 121 days and 124 days, which is longer than the 30 days written in the regulations.  

AML and GAAP compliance

Central to Dyer’s disciplinary was the fact he had consistently failed to remain up-to-date and comply with his professional obligations. He acknowledged these failings to the tribunal but he did little to nothing to address them. 

Dyer’s understanding of MLR requirements came under question at the first QAD visit in May 2016. His understanding hadn’t improved by the follow-up visit in 2017 and Dyer had not changed any of his procedures. The reviewer was handed three customer due diligence forms for three clients, but these were incomplete and weren’t a glowing endorsement of Dyer’s ability to conduct a proper AML risk assessment. 

The other red flag was the number of errors he made in financial statements, such as the balance sheets, profit and loss accounts not being in the right format and the statements did not include disclosures notes or a statement of compliance. 

Some of Dyer’s knowledge gaps could have been bridged by using accounts production software, but the investigation committee reported that he did not use any. 

The QAD suggested that Dyer should go on a training course for AML and GAAP, and while he accepted this, there was no evidence that he had actually done so. 

Tribunal conclusion

Dyer apologised to the tribunal for the mistakes that he should have been aware of and blamed his lack of training over the past two years on Covid and how the pandemic made it difficult for him to do in-person training. 

The sole practitioner reiterated that he’d taken on board the complaints; submitting prior to the hearing that tax refunds no longer went through his account, any money received was repaid to clients within a day or so, risk assessments were being completed and he showed proof that the company accounts he was handling were now FRS 102 compliant. 

However, the tribunal viewed Dyer’s failures as egregious and highlighted how his AML oversights could pave the way for criminal offences. 

The tribunal said Dyer had repeatedly failed to address his failures or follow through with QAD suggestions and corrective actions. 

It concluded that the nature of his failings was wide-ranging and the risk of him repeating these errors was high. The tribunal said that “if Mr Dyer retained his membership of ICAEW, he would simply continue in much the same vein as before”.

It decided to strip Dyer of his ICAEW membership and while there was no fine, the tribunal ordered that he pay costs of £12,316. 

Alison Wood, Associate at Blake Morgan LLP said: 

Under the ICAEW's guidance on sanctions, had the complaints been taken individually, Mr Dyer could have expected to get a reprimand (or severe reprimand in respect of his admitted breaches of MLR), a fine and/or an order for remedial training. However, as a whole, the tribunal was of the view that the only appropriate sanction was exclusion from membership, expressing concerns about the lack of insight demonstrated by Mr Dyer and the risk of repetition.

The case highlights the importance of seeking expert advice as soon as any concerns are identified and, at the very least, ensuring appropriate representation at any hearing and throughout disciplinary proceedings. Practitioners must be cautious when making submissions and should not underestimate the importance of evidencing insight and remediation. Had Mr Dyer been better advised, a more favourable outcome may well have been achieved.   

Alison Wood is a consultant with Blake Morgan. The team is available to assist with any disciplinary, regulatory and compliance matters arising in the accountancy profession - click here if you require any of their services

Replies (55)

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the sea otter
By memyself-eye
24th Jan 2022 12:39

a member since 1969! How old is this guy?

Time to hang up his pencil!

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Replying to memyself-eye:
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By AnnAccountant
24th Jan 2022 14:19

There tends to be a number of elderly accountants who end their career in the disciplinaries - and they often note that the old accountant doesn't have the money to pay a fine.

Probably the result of a long life spending money on divorces, eating out and going to the car showroom. Often tends to be the case. I see it in a number of professionals who are still working in their 60s and 70s. All at risk of mistakes and/or being leant on by unscrupulous clients who can smell their declining faculties and desperation.

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Replying to AnnAccountant:
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By Carol Jefferis
24th Jan 2022 19:48

Gee Ann, thanks for reminding me I need to eat out more, I can tick all your other boxes.
Seriously though we older souls aren't all bent or gaga. There a few people out here who have a good idea of our limitations and are functioning within them to a high standard and keeping up to date in our field.
I think being a sole practitioner can be just as big a risk factor for poor professional performance - being spread too thin in an increasingly challenging world with no one to bounce ideas off or peer review work.
But hey, you hold on to ageist prejudices if it makes you happy.

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Replying to Carol Jefferis:
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By whatdoyoumeanwashe
25th Jan 2022 10:33

I don't think it's so much about age, but anyone who is planning on not running their practice for much longer could be prone to letting their guard down, since the consequences of getting struck off diminish. You also gain a better understanding of what you can get away with as your experience increases. There are very minor things that I or my clients do which made me lose sleep when I first started but now I don't worry about them (like perhaps "correcting" a client's tax code without calling HMRC). Clearly some people take that to extremes!

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Replying to whatdoyoumeanwashe:
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By Hugo Fair
25th Jan 2022 11:42

The potential threat of getting struck off shouldn't be what keeps the professional on the straight & narrow ... that's achieved by a combination of personality type & experience (so a belief in the values of honesty, integrity, consistency and so on). And these don't diminish with age even if knowledge or acuity may.

But I'm worried you think "correcting" a client's tax code without calling HMRC is a "minor thing" ... you not only have no legal right to do this but will be storing up extra work for yourself and your client due to the lack of synchronisation with HMRC's data.

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Replying to Hugo Fair:
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By whatdoyoumeanwashe
25th Jan 2022 11:56

Well you carry on worrying if you've nothing better to do!! Not that I need to explain my actions to you, but the example I gave was a perfectly reasonable course of action under the circumstances at the time, and solved a significant problem that HMRC were unable to solve themselves. I also once drove at 80 miles an hour on the motorway.

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Replying to Hugo Fair:
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By Paul Crowley
25th Jan 2022 12:21

Not a big deal
I BR my wages and my wife's wages every year and ignore the daft codings we get
HMRC are very regularly wrong
Clients with a once off expenses claim get the same amount coded each year for several years
Same issue with p11d. No benefits but benefits from prior employment stick for years

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Replying to Paul Crowley:
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By whatdoyoumeanwashe
25th Jan 2022 12:37

You ought to be careful going around doing things with no legal right to do so.

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Replying to whatdoyoumeanwashe:
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By Hugo Fair
25th Jan 2022 13:02

I'm well aware that HMRC get tax code notices 'wrong' (and indeed generate them via imperfect software), but that doesn't give you the right to unilaterally break the rules ... two wrongs and all that!

My point was less to do with pointing out the error of your ways (of which you're obviously fully aware), but that - by failing to follow the correct procedure (of notifying HMRC of their error and so getting the tax code amended) - you are then operating PAYE for that individual using a different baseline to HMRC. And this can (not always) leads to considerable confusion at HMRC's end ... which ends up with you and your client spending unnecessary time bringing the two systems back into line with each other.

So the 'worry' was on your (not my own) behalf ... and you're welcome to ignore it.

My more subtle point was that you lost the moral high ground (in suggesting that it is only the threat of being struck off that keeps a professional on the straight & narrow) when you go on to admit to bending the rules if it suits you.

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Replying to Hugo Fair:
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By Paul Crowley
25th Jan 2022 16:05

HMRC PAYE computer codings work on triggers
When the triggers stop HMRC leaves the last bit of rubbish in place
EG
No p11d this year? leave it at last years figure
No p11d for three years? leave code restriction at three years ago figure

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Replying to Paul Crowley:
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By Hugo Fair
25th Jan 2022 16:34

Well that's not the way the triggers are supposed to work (or, to the best of my knowledge, how indeed they do operate) ... but the software driving the triggers is most certainly incomplete-verging-on-broken in several aspects.

The most infamous example being its inability to differentiate between a one-off payment and regular earnings. So for example, an employee receiving salary of £3k per month but who also receives an annual bonus of £10k in May is assumed by the software to now be on an annual salary of £156k p.a.!

HMRC do know about the limitations (aka failings) in this part of their software, which is why they've made it much easier to get a tax code quickly corrected.

The converse is that their software now looks for any 'mismatches' between the tax code they told your Payroll to use and the one that the Payroll reports (via each FPS) as being used ... and these mismatches are tracked (partly so as to send you 'warnings' - but reputedly also as part of their intentions to profile Payroll service providers and agents). Big Brother is watching!

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Replying to whatdoyoumeanwashe:
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By Paul Crowley
25th Jan 2022 16:01

Disagree
I have every right to pay more tax than HMRC want
Been doing it for 20 years
Odd really that HMRC have never bothered getting excited about it

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Replying to Paul Crowley:
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By johnjenkins
25th Jan 2022 13:17

I always overlook the wrong codes that come out. Agent strategy was supposed to get rid of the wrongs as we would be allowed to alter where necessary. No doubt MTD will correct everything.

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Replying to Hugo Fair:
By cfield
26th Jan 2022 00:36

Well they can hardly be more wrong that the rubbishy tax codes we see from HMRC these days. The helpline staff tend to amend them on the phone without further ado so they obviously have no more faith in them than we do.

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Replying to cfield:
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By Hugo Fair
26th Jan 2022 12:07

Yes, but you're missing the point.
I not only don't dispute that you see "rubbishy tax codes .. from HMRC these days", I've already agreed with this (and even given one example of why this can happen - and 'admitted' that the underlying software generating the codes is fairly broken).

So, I'm not saying that the codes are right or that you should just accept them ... I'm saying you (or the taxpayer) should do exactly what you've suggested - get the helpline staff to amend the tax code (or even more simply change it online).

The point is that there's no point in using a tax code that's different to what HMRC are expecting (according to their records) ... so, if it's wrong, get them to change it and don't just declare UDI (storing up problems for the future)!

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Replying to Hugo Fair:
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By johnjenkins
26th Jan 2022 12:18

This is where the problem is. More and more agents are using their own knowledge rather than incorrect HMRC information. The gap between us and them is ever widening and unless HMRC get rid of IR35 and QU for the under £85k business, then HMRC will go into self destruction.

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Replying to Hugo Fair:
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By whatdoyoumeanwashe
26th Jan 2022 12:24

I can't quite believe this conversation is still going on, but since it is I have two points to make:
1. I'm trying to make a living, and I can't afford to waste time on the phone to HMRC for such petty matters.
2. The circumstance I was thinking of originally was basically this: HMRC owed a client of mine a couple of thousand pounds of SMP. The company (just 2 directors, husband and wife) had no PAYE liability to offset it against and after a year of calls, letters, forms etc, HMRC still failed to repay the money despite promising to do so again and again. I wasted huge amounts of time that I didn't feel able to bill my client for, and still we had no solution. So I put them on a BR tax code for a couple of months, creating a PAYE liability to offset the debt HMRC owed my client's company, and then the directors' income tax was trued up via their self assessment. It worked a treat. My only regret is not doing it sooner. Hugo, I think you should worry about something else.

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Replying to whatdoyoumeanwashe:
By cfield
27th Jan 2022 12:46

Well that really is storing up problems, because a) the SMP rebate is owed to the company, not the taxpayer, and b) the correct tax will come out in the wash when you do his Self Assessment and deduct the PAYE, so then you'll be back to Square One.

It would probably have been better to knock it off the corporation tax bill and write HMRC a letter requesting an offset. That worked a treat for me once, although It was a duplicate payment in that case, not SMP. Of course, it took a while for them to action it, but cashflow-wise it was done and dusted.

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Replying to cfield:
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By whatdoyoumeanwashe
27th Jan 2022 12:57

You've misunderstood. It's done, two years ago, and as I said, it worked a treat.

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Replying to whatdoyoumeanwashe:
By cfield
28th Jan 2022 15:20

Well you might think it's done but it sounds like you have some loan account entries to do because the wife should have had the SMP from her company via the payroll. Hence, if she got an artificial reduction in her Self Assessment tax bill by claiming PAYE that was never paid (as it was offset against the SMP) then effectively she's had it twice, plus the extra 3% for NI, and owes the company.

Not only that, but if the husband got the benefit of PAYE that was never paid on his own Self Assessment, then they both owe the company for it.

Like I said, best to offset against corporation tax, just as we do with CIS.

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Replying to cfield:
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By whatdoyoumeanwashe
28th Jan 2022 16:12

I'm only responding to this because I'm stuck at home with kids and covid. You've misunderstood. Firstly, the wife got her smp from the company via payroll at the appropriate time.
The company has a PAYE debtor of say £1,000. I put the directors on a BR tax code for a few months, so they receive say £800 net salary instead of £1,000 each month. I do this for say 3 months until the PAYE debtor is used up (we don't need to pay hmrc the £400 of PAYE each month during this because they owe the company) and becomes a small creditor of £200, which the company settles in the normal way. When we prepare the directors personal tax return their P60s show say £600 income tax deducted at source and thus reduces their overall income tax bill by £600, so they effectively receive £600 each less from the company and this is offset by a £600 lower self assessment Bill. No one owes anyone anything and everything has been taxed correctly.

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Replying to cfield:
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By whatdoyoumeanwashe
27th Jan 2022 12:57

You've misunderstood. It's done, two years ago, and as I said, it worked a treat.

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Replying to Hugo Fair:
By cfield
27th Jan 2022 12:29

Hugo Fair wrote:

Yes, but you're missing the point.
I not only don't dispute that you see "rubbishy tax codes .. from HMRC these days", I've already agreed with this (and even given one example of why this can happen - and 'admitted' that the underlying software generating the codes is fairly broken).

So, I'm not saying that the codes are right or that you should just accept them ... I'm saying you (or the taxpayer) should do exactly what you've suggested - get the helpline staff to amend the tax code (or even more simply change it online).

Hugo, did I say I changed tax codes unilaterally? I think you're mixing me up with another poster. I enter the rubbishy codes on my payroll software anyway as most of my clients are below the NI threshold and it makes no difference. I only bother phoning the helpline if a client with a PAYE job queries their code, it is causing problems with their net pay and it's plainly wrong, in which case they get billed for the extra work. I usually try to do 3 or 4 of them together to cut down on the dead phone time, listening to their interminable guidance, being warned about dogs barking (perhaps Rebecca B should do this before her webinars) and waiting ages on hold.

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Replying to AnnAccountant:
FirstTab
By FirstTab
25th Jan 2022 19:41

60s and 70s is not old.

The world leader Joe Biden is 79
Nancy Pelosi is 81. She has a sharp mind.

I do not understand, when people here say I am in my 6os I am retiring. I have had enough.

I think your perspective on being so ageist will change as you become old at 60.

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Replying to FirstTab:
By cfield
26th Jan 2022 00:47

FirstTab wrote:

The world leader Joe Biden is 79


I wish people would stop calling the US President "world leader" or "leader of the free world". It's so incredibly patronising, not to mention totally outdated as it was originally coined during the Cold War for propaganda purposes. The way America is going, the free world bit will soon be nothing but a bad joke.
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Replying to cfield:
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By whatdoyoumeanwashe
26th Jan 2022 08:23

I completely agree. No one is world leader and that's something we should all be very pleased about.

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Replying to AnnAccountant:
By cfield
26th Jan 2022 00:29

60s and 70s? Excuse me, young miss. Plenty of us are in our 60s and manage to stay on top of our game. We're not all ready for the knackers yard. I for one have got just as much zest as I had in my 30s and keep on top of my CPD as much as all you young whippersnappers. There is a common assumption amongst the young that us old greybeards know nothing about IT. As I always tell my young nephew, it was my generation that invented the IT revolution. In fact, I was writing macros in Lotus 1-2-3 back in the mid-80s.

This guy, however, must be in his late 70s or early 80s. He's obviously shown no sign of adapting to the modern world and probably still uses dusty old ledgers. His clients are probably as old as him. He is unlikely to have a website and probably hasn't taken on any new clients for many years. His existing clients will no doubt carry on using him whether he is a member or not. They should have advised him to retire, not wasted their time trying to teach him AML and end up having to shame an old man who was probably quite good in his day.

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FirstTab
By FirstTab
24th Jan 2022 13:09

ICAEW what reputation? Such big heads in Ivory Tower.

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Replying to FirstTab:
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By Hugo Fair
24th Jan 2022 17:37

Never mind that there appears to be no question of dishonest behaviour or of invalid accounting treatments - just a bunch of boxes failing to be ticked (albeit some more important than others).
I guess he'll save on annual fees and provide his services within the 'unrepresented' segment of the market - where the quality of his work will no doubt result in a marked improvement over their previous DiY efforts!

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Replying to Hugo Fair:
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By johnjenkins
25th Jan 2022 10:35

No mention of investigations from HMRC. Makes you think perhaps he did get a few things right.

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Replying to FirstTab:
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By Paul Crowley
25th Jan 2022 16:09

"ICAEW what reputation? Such big heads in Ivory Tower."
Really?

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By ireallyshouldknowthisbut
24th Jan 2022 14:10

Sounds like a horrible end to a long career.

Another reminder (should I not get it every time we take on work from the 'old boy who has lost their way') that its not something to fiddle about with in semi-retirement as my ability to act declines, and no doubt my judgement of my own ability becomes impaired.

As I was explaining recently its not the sort of job you can do 3 mornings a week, you need two of them just to keep up with what's going on.

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Replying to ireallyshouldknowthisbut:
the sea otter
By memyself-eye
24th Jan 2022 15:40

True - I quit at 67, not because of declining faculties, just got fed up of all the cr*p

Now where did I park the Bentley?

Or was it a Roller....

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Replying to ireallyshouldknowthisbut:
paddle steamer
By DJKL
25th Jan 2022 10:29

You have to narrow your offering, not take on certain work etc

Whilst no longer in practice one of the reasons for that was I did not believe I could keep up to date and wanted to pack in before I started making mistakes, I would be spending circa 5 hours a week on client work and five hours a week on admin and CPD.

It is the unknown unknowns that will snare you in the end.

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Replying to DJKL:
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By whatdoyoumeanwashe
25th Jan 2022 10:38

I guess it's easier to keep up to date if you have a specialism, even a very simple one. As a GP with a declining pool of diverse clients, it's definitely hard and ultimately will stop being worthwhile.

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Replying to whatdoyoumeanwashe:
paddle steamer
By DJKL
25th Jan 2022 11:35

It was always thus, when I did work full time in practice (a two partner , six to eight staff firm) we split the niches, each taking responsibility for different things thus spreading the load.

Law firms always did this, my father would be fine with your CTT work and trusts, great at conveyancing re your landed estates and their boundaries, but absolutely useless if you wanted divorced or the matter involved court work. (His court appearances in total had been defending someone drunk in charge of a bicycle and defending a poacher)

No single person, imho, can keep fully up to speed with all changes impacting even the basic smaller clients let alone all clients.

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Replying to ireallyshouldknowthisbut:
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By Mister O
25th Jan 2022 11:15

I’m managing fine, thanks. But then I don’t have to spend half my time filling in forms and ticking boxes for ICAS any more. I can just get on with my job!

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By carnmores
24th Jan 2022 15:53

And Blake Morgan promoting themselves again without much recognition of the facts

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Replying to carnmores:
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By Hugo Fair
24th Jan 2022 17:30

Indeed, I can't see what the mini-advert at the end does to illuminate any aspect of the rest of the article.
Reminded me of what the second-hand car trade refers to as a 'cut and shut job'!

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By Chelseabean
25th Jan 2022 10:39

Yet those at the top of KPMG, PWC etc who really bring the profession into disrepute through their audit gross negligence and public admission of dishonesty and lying get away untouched with the biggest crimes in the profession.

Just like HMRC, simply go after the low hanging fruit and the ICAEW and ACCA can tick another box of job well done.

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By 4b4
25th Jan 2022 10:42

I bet none of the big four partners will be cashiered by ICAEW due to their 'dodgy' auditing failures though?

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Replying to 4b4:
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By paul.benny
26th Jan 2022 12:59

Apart, that is from the engagement partner for BHS, for example, and quite probably Carillion, Patisserie Valerie, Conviviality, and those KPMG clients where records were falsified.

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By Mr J Andrews
25th Jan 2022 10:45

One wonders what clientele this sole practitioner OAP was dealing with - Over a quarter of a million £ client money paid into his personal bank account over 5 years.
Dyer may have had an understanding with his clients that fees could be deducted from their tax refunds into his personal account but the contradictory statement that these refunds were not significant - but followed by the finding of no adequate records, with continued failure - are indeed something his clients should be made aware of.

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Red Leader
By Red Leader
25th Jan 2022 10:52

Reminds me of an elderly accountant I knew who was registered for audit. The final visit from ICAEW determined that she had to have hot file reviews before signing off any more.

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By thomas34
25th Jan 2022 12:05

This is a sad story really and atypical of the usual transgressions we read about where client monies are stolen or false profits reported to HMRC. I myself joined the ICAEW in 1969 and am retiring on 31 March. I perceived as long ago as 2004 that the ICAEW probably posed more of a risk to my business than HMRC and resigned my membership. I see the day of the sole practitioner coming to an end simply because of the inability to make a decent living what with the amount of unbilled/unbillable time due to HMRC errors, MTD for SA (if it happens) etc.

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Replying to thomas34:
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By johnjenkins
25th Jan 2022 12:17

So technology substituting experience?
Problem is good technology comes from good experience. We are back to the SISO scenario.

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Replying to thomas34:
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By Paul Crowley
25th Jan 2022 12:35

"This is a sad story really and atypical of the usual transgressions we read about where client monies are stolen or false profits reported to HMRC."
Disagree
Never see them on ICAEW disciplinaries for ordinary cooking UK based practioners
And that is the problem
Not enough bad stuff going on so the disciplinaries look for anything they can find just too validate existance

Nothing taken, no loss to client just a few accounts without the rubbish disclosures that FRS 105 and Micro accounts got rid of anyway

I have FRS102 clients that prefer the detailed profit and loss and detailed Balance sheet that the software provides over the pages and pages of pointless disclosures of the 102 accounts that I have to provide as final accounts.

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Replying to Paul Crowley:
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By thomas34
25th Jan 2022 13:02

Not sure what you're trying to say Paul. Unless he was a first time pass student he must be in his mid 70s. We don't know his financial situation and whether he needs to work for the money. We don't know about possible stress levels. It's easy to be critical of someone who simply can't cope with the raft of regulations imposed upon us practitioners. And what does "ordinary cooking UK based practioners" mean anyway?

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Replying to thomas34:
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By Hugo Fair
25th Jan 2022 13:12

Although I'm sure Paul can reply for himself, I read it as meaning that the PBs don't seem to go after (or at least don't find and penalise) the odd bent accountant who straightforwardly cooks the books - and obviously leave the big boys & girls alone (different story) - so are left chasing down failures in box-ticking in order to justify their existence?

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Replying to Hugo Fair:
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By Paul Crowley
25th Jan 2022 16:21

Correct interpretation
Most accountants AML achieves very little
Accountants have been criticised for submitting pointless, covering the tail reports

Massive cash movements hit the banks and legal types up to 18 months before I see any records
Hence my report appears pointless and tail covering, the others got there first

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