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The [hypothetical] practitioner provides advice to debtors under the IP exclusion from FCA authorisation. That exclusion only applies where the IP is advising in reasonable contemplation of an insolvency appointment. If during the course of an interview, the practitioner establishes that there is a conflict of interests which would prevent them from accepting an insolvency appointment, should they terminate the appointment, as they are no longer providing advice ‘in reasonable contemplation of an appointment’ ?

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