had thus avoided the very significant financial losses and liabilities that the respondents had incurred. The SDT noted that from the summer of 2010 the firm had to a large extent been managed financially by the bank and/or its on-site representatives. The respondents had been led to believe that essential business expenses would continue to be met: insurance is an essential business expense. The respondents had been unaware for some time that the premium had not been paid. While the SDT noted that the size of the premium in the present case was very large, that alone could not be the determining factor -- whether or not a waiver were in due course granted. The respondents had initially not acknowledged their liability to pay, but had now done so. The SDT was satisfied that they had co-operated with the SRA. No payments had been made towards the premium. In that respect, the SDT noted that all of the respondents had suffered significant financial losses as a result of the closure of the firm and its administration. The most significant factors in determining sanction in the present case were the quite exceptional background circumstances, as set out above. The respondents were not personally culpable for those circumstances, although they were responsible for non-payment of the insurance premiums. They had tried to protect their clients. Had they been personally culpable, the sanction would have been more severe. However, in all of the circumstances, a financial sanction was appropriate and proportionate. The SDT