Between January 2007 and January 2009, a number of serious failings by Park Row were identified in relation to the suitability of its customer advice. These include:

• Failing to ensure that advisers properly evidenced the suitability of sales;
• Failing to ensure advisers offered suitable advice to customers at all times and for all products;
• Failing to ensure that its systems and controls were adequate; and
• Consistently failing to take action to rectify these failings despite the fact that concerns were highlighted to the firm on a number of occasions.

Peter Sprung was chief executive of Park Row and between January 2007 and January 2009 his conduct fell short of what was expected of a senior manager of an authorized firm. He failed to take steps to ensure that Park Row and its advisers properly evidenced the suitability of sales and that sales were actually suitable, in particular in relation to pension advice. Advisers sometimes provided advice in relation to certain products on which they were not authorized to advise and it was identified that there was a danger that some of them may have selected products based on the fact that they would receive higher commission. Sprung also failed to ensure that the systems and controls were adequate to manage the risks to the business, and to ensure the suitability of advice through compliance checks.