FINAL NOTICE

To:

The Proper Brand Limited

Of:

The Farm House
East Crieffvechter Farm Cottage
Crieff
PH7 3QR

ACTION

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

2.
The Authority issued to TPBL 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 TPBL’s Part 4A permission.

3.
TPBL 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 TPBL’s Part 4A 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 TPBL dated 16 May
2018;

The Proper Brand Limited





25 July 2018

“the Return” means the CCR007 return for the period ended 31 March 2017,
which TPBL was due to submit to the Authority by 17 May 2017;

“the suitability Threshold Condition” means the Threshold Condition set out in
paragraph 2E of Schedule 6 to the Act;

“TPBL” means The Proper Brand Limited;

“TPBL’s Part 4A permission” means the permission granted by the Authority to
TPBL pursuant to Part 4A of 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 TPBL dated 24 April
2018.

REASONS FOR ACTION

6.
On the basis of the facts and matters and conclusions described in the Warning
Notice and in the Decision Notice, it appears to the Authority that TPBL is failing
to satisfy the suitability Threshold Condition, in that the Authority is not satisfied
that TPBL is a fit and proper person having regard to all the circumstances,
including whether TPBL 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 TPBL has failed to comply with the regulatory requirement to
submit the Return. TPBL has not been open and co-operative in all its dealings
with the Authority, in that TPBL has failed to respond adequately to the
Authority's repeated requests for it to submit the Return, 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 under the regulatory system.

8.
These failures, which are significant in the context of TPBL’s suitability, lead the
Authority to conclude that TPBL 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 TPBL was
granted a Part 4A 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 TPBL in accordance with section 390(1) of the Act.

The Proper Brand Limited

25 July 2018

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 TPBL 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 Jacqui
Dankyi at the Authority (direct line: 020 7066 2102).

Anna Couzens
Enforcement and Market Oversight Division