What an independent file review gives a small firm, and what it does not

1 day ago

4 min read

On 3 September, Legal Futures reported the findings of an independent serious event review into the SRA's handling of the PM Law Group. The review was carried out by Jenner & Block and commissioned by the SRA, at the prompting of the Legal Services Board. PM Law was a group of 12 connected practices that shut down suddenly at the start of February and was then intervened in by the SRA.

I am not comparing PM Law with a small firm. It was a group of 12 practices with a centralised structure. But one line from the review applies to every firm that keeps files, ledgers, supervision notes and complaints in different places.

Fresh eyes with an independent file review

Information is not oversight

Jenner & Block's central finding was "a failure to aggregate information". In the review's words: "The SRA held more information about the PM Law Group than was ever drawn together into a single, coherent risk picture." The knowledge, it said, "was fractured". It was spread across different teams, systems and individuals.

The review also found that a 2025 investigation was "insufficiently rigorous". It was closed on the basis of explanations from the group's chief executive that were "not independently verified".

Two lessons follow for any firm, and neither depends on size.

The first is that holding information is different from using it. Most small firms hold plenty. File notes, the client ledger, the supervision log, the complaints register, the risk assessment. Whether anyone has ever read them side by side is another matter.

The second is that an explanation is not evidence. "We always do that" is an explanation. A file that shows it is evidence.

What an independent file review is

An independent file review is exactly what it sounds like. I take a sample of your files, read them as an outsider, and tell you what they show. I look at whether the file tells a complete story to someone who has never met the client, whether the record supports what your policies say you do, and whether the gaps are one-offs or patterns.

You get my findings in plain English: what is working, what is not, and what to fix first. The aim is that you can find the three things that matter without wading through a document written to impress.

We agree the scope and the format of the findings before I start, so there are no surprises on either side.

What a small firm gets from it

Fee-earning time back. An internal file review takes someone off client work, usually the person least able to spare the time. An outside reviewer does the reading, so your people stay on billable matters.

An objective view. Colleagues find it awkward to criticise each other's files. An independent reviewer has no history with the fee earner and no reason to soften the finding.

One person, every time. You work with me directly, from the first conversation to the final report. There is no handover to a junior consultant, and nobody to explain your firm to twice.

Preparation, not surprises. If you have a Lexcel or SQM assessment, a Legal Aid Agency audit or an SRA visit approaching, the review shows you the gaps while there is still time to close them. If something bigger is coming, such as a mock audit, the review is a sensible first step.

Remote delivery. I deliver my mock audits and consultancy remotely as a matter of course, so your location in England and Wales is not a barrier. We can agree at the outset how a review of your files would work in practice, including how files are shared securely.

What it does not do

An independent review does not guarantee that you will pass an assessment, and it does not replace your own supervision. It gives you a clear picture on one date. The supervision, the file reviews and the follow-through remain yours.

It also does not mean I run your compliance. The aim is that your COLP and COFA can see what I saw, and can keep seeing it after I have gone.

On cost

My fees are on an agreed basis, quoted individually after we have talked about the size of your firm and what you want reviewed. They are exclusive of VAT. There is no published price list, because a four-fee-earner firm and a sole practitioner need different things.

Start with a conversation

If you would like an independent view of where your firm stands on compliance, I offer a free health check, with no obligation. Get in touch and we can arrange a time to talk it through.

Book your free health check

The contact page is an enquiry form, so please put "free health check" in the message subject and I will pick it up straight away.

Ashley Barwick is a Fellow of the Chartered Institute of Legal Executives and a Law Society accredited Lexcel Consultant. This post is general information and does not constitute legal advice. Fraxinus Business Associates is not authorised to provide legal advice.