Paul Harfitt
Solicitor
108766

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 6 July 2026

Published date: 13 July 2026

Firm details

Firm or organisation at date of publication

Name: Paul Harfitt & Co

Address(es): The Old Bank, 20 High Street, Wem, Shrewsbury, SY4 5AA

Firm ID:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1. Mr Paul Harfitt ('Mr Harfitt'), an owner and director of Paul F. Harfitt & Co (the Firm), agrees to the following outcome to the investigation of his conduct by the Solicitors Regulation Authority (SRA):

1. he is rebuked
2. to the publication of this agreement
3. he will pay the costs of the investigation of £300

2. Summary of Facts

2.1. On 18 May 2025, the SRA commenced an investigation into the conduct of Mr Harfitt after information arose in a media report which stated that Shropshire Council had issued Mr Harfitt, a recognised sole practitioner and the firm's COLP and COFA, with a civil financial penalty of £8,400 for carrying out property management activities without being a member of an approved Client Money Protection (CMP) scheme.

2.2. The SRA's investigation identified the following issues:

2. Over the period from October 2008 onwards, rental income of £550 per calendar month was received into the firm's client account in respect of one property. In addition, from September 2020 onwards, further rental income of £450 per calendar month was received into the client account in respect of another property. These payments were collected and processed on a regular monthly basis. This activity did not form part of regulated legal services and, as such, amounted to the improper use of the client account as a banking facility, contrary to the SRA Accounts Rules.

2.3. There is no evidence of client loss or misapplication of funds, and a proportion of the funds were related to tenancy-related legal work. The activity was limited to two longstanding clients and has since ceased.

3. Admissions

3.1. Mr Harfitt makes the following admissions which the SRA accepts:

1. He received, held and operated rental income through his firm's client account in circumstances where the activity did not relate to an underlying legal transaction or the delivery of regulated legal services, thereby using the client account as a banking facility, in breach of:
   • Solicitors Accounts Rules 1998 (until 6 October 2011)– Note (ix)
   • Solicitors' Code of Conduct 2007 (until 5 October 2011)– Rule 1.06
   • SRA Accounts Rules 2011 (until 24 November 2019) – Rule 14.5
   • SRA Accounts Rules (2019) – Rule 3.3
   • SRA Principles 2011 (until 24 November 2019) – Principle 6
   • SRA Principles 2019 – Principle 2

4. Why a written rebuke is an appropriate outcome

4.1. The SRA's Enforcement Strategy sets out its approach to the use of its enforcement powers where there has been a failure to meet its standards or requirements.

4.2. When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by Mr Harfitt and the following mitigation which he has put forward:

1. He has cooperated fully and promptly with the investigation and made early admissions
2. there is no evidence of dishonesty, client loss, or personal gain. He regularly accounted to clients, and there is no indication that funds were misapplied or improperly withheld.
3. the issue was limited to rent collection activity for two longstanding clients and did not extend to other clients or areas of his practice. He ceased using the client account for rent collection and property management activities following the hearing.
4. Mr Harfitt has no adverse regulatory history and the conduct was isolated to these two matters.

4.3. The SRA considers that a written rebuke is the appropriate outcome because

1. Mr Harfitt had direct responsibility for the conduct in question and for ensuring that the firm complied with the requirements of the Accounts Rules and wider regulatory obligations, particularly in his role as a sole practitioner, COLP and COFA
2. the improper use of the client account occurred over a prolonged period, during which it was used as a banking facility for non legal property management activities, contrary to the safeguards expected for handling client money.
3. using the client account for non legal financial activity carries a risk of undermining public confidence, as the public is entitled to expect that solicitors will use client accounts strictly in accordance with the regulatory framework governing client money.
4. the SRA enforcement strategy states that we take account of the circumstances and a rebuke is appropriate when:
   1. the conduct or behaviour is reckless as to the risk of harm/regulatory obligations.
   2. there is a low risk of repetition.
   3. some public sanction is required to uphold public confidence in the delivery of legal services.

5. Publication

5.1. The SRA considers it appropriate that this agreement is published in the interests of transparency in the regulatory and disciplinary process. Mr Harfitt agrees to the publication of this agreement.

6. Acting in a way which is inconsistent with this agreement

6.1. Mr Harfitt agrees that he will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

6.2. If Mr Harfitt denies the admissions or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

6.3. Denying the admissions made or acting in a way which is inconsistent with this agreement may also constitute a separate breach of principles 2 and 5 of the Principles and paragraph 7.3 of the Code of Conduct for Solicitors, RELs and RFLs.

6.4. Acting in a way which is inconsistent with this agreement may also constitute a separate breach of principles 2 and 5 of the Principles and paragraph 3.2 of the Code of Conduct for Firms.

7. Costs

7.1. Mr Harfitt agrees to pay the costs of the SRA's investigation in the sum of £300. Such costs are due within 28 days of a statement of costs due being issued by the SRA.