Qlts Qualification

Posted : admin On 4/10/2022

I have passed the QLTS examinations and am now on my way to getting qualified as an English solicitor. As I’ve mentioned elsewhere before, I managed to pass both the Multiple Choice Test (MCT) and the Organised Structured Clinical Examinations (OSCE) on my first attempt with good scores despite only having just two weeks of preparation time for each of them. I know how challenging it can be for a practising lawyer to take on the QLTS, so hopefully this note on what worked (or didn't work) for me will help other current and prospective candidates with their preparations for the exam.

As a general disclaimer, I should state here that my perspective is that of a Singaporean disputes lawyer (i.e. trained in the common law and having English as my first language), so what worked for me, may not work so well for others. I should also state that I had by no means acquired perfect scores (MCT 76%; OSCE 86%), but I think I had achieved a good result with what little time I had.

Coronavirus impact on QLTS assessments. The next sitting of the QLTS multiple choice test is due to take place on 13 January, in the UK and other locations around the world. Together with Kaplan, our QLTS assessment provider, we are considering the impact on the exam of the UK-wide Covid-19 lockdown and changing restrictions in other countries. QLTS Assessments. Overview Get a quick grasp on the basic elements of the QLTS assessments; Taking the Assessments Learn more about exam dates, fees and locations; Format Read more about the structure and style of the assessments; SQE vs QLTS – What are the Differences? Learn about the new route for qualification that will replace the QLTS in. QLTS provides a route for lawyers from other recognised jurisdictions, and barristers from England and Wales to qualify as solicitors of England and Wales. Updated 7th January 2021 - COVID-19 Update for MCT assessment candidates. The Qualified Lawyers Transfer Scheme (QLTS) provides an opportunity for lawyers from various countries around the world to qualify as solicitors in England and Wales. The scheme is administered by the Solicitors Regulation Authority (SRA), the regulatory body of the Law Society of England and Wales. What is the Qualified Lawyers Transfer Scheme (QLTS)? The QLTS offers lawyers from all over the world a unique opportunity to advance their legal career and obtain the most prestigious title in the legal profession, an English solicitor. There is no training or experience.

The Core Materials

Books

I have been told by several past candidates that the books of choice should be the Oxford University Press (OUP) Concentrates (see: https://global.oup.com/academic/content/series/c/concentrate-conc/?cc=sg&lang=en&). However, I ultimately found the OUP Concentrates to cover way too much ground. With only two weeks of preparation time, I had to find another way.

What I used instead were the Law Answered notes, specifically the GDL Answered notes (for the MCT) and the LPC Answered notes (for the OSCE). You may find them here at https://www.lawanswered.com/. They are essentially concise (but high quality) notes made by past candidates for the Graduate Diploma in Law (GDL) and the Legal Practice Course (LPC) in England and Wales.

In my experience, only the core guides are needed; there is no need to get the accompanying case books as well. I found the notes to be good enough that I had no need to spend time making my own short notes. The only ones I found lacking were the notes on property practice and business law (specifically the partnership law section). I would therefore recommend getting the OUP Concentrates for those subjects as a supplement to the Law Answered notes.

You may be able to get copies of older versions from past candidates, but I would highly recommend purchasing the latest version from the website. You will not want to spend time researching the latest legal developments and tax rate revisions in the UK just to figure out what the older notes may have missed.

Practice Tests

For the MCT, I only used the sample questions found on the Kaplan website: https://qlts.kaplan.co.uk/the-assessment/mct. This is just enough to give you a flavour of what questions you can expect to come out, but not much else. If you wish to be fully prepared, I would suggest signing up with a course provider that can provide you with comprehensive mock papers.

Qlts Qualification

For the OSCE, apart from the Kaplan sample materials (https://qlts.kaplan.co.uk/the-assessment/osce) and the QLTS Advantage materials (elaborated on below), I used the past papers and model answers from the CILEX website (Chartered Institute of Legal Executives): see https://www.cilex.org.uk/study/information_for_students/exams/past_papers. Both the Level 3 and Level 6 papers have subjects relevant for the OSCE. I did not have the time to attempt the papers, so all I did was study the model answers to about three sets of past papers. I found that to be very useful for the writing component of the OSCE exams, as the model answers are designed to be concise answers for practical questions that may be posed by a client.

Courses

Some have also asked whether signing up for a course is a good idea. I did not sign up for one for the MCT, but I did sign up for the QLTS Advantage course for the OSCE (https://www.qltsadvantage.com/).

I found the QLTS Advantage course to be excellent for the OSCE. It does not provide you with good study notes (you should stick with the Law Answered notes), but where it truly shines is its provision of practice questions with full-length video explanations from actual law professors and tutors on how to best tackle them. The revision videos were also pretty comprehensive, with special focus on the areas that are likely to be tested on. I found myself learning a lot in a short amount of time simply by watching the videos (often at 2x playback speed). It is not cheap by any means, but you really get what you pay for.

Having said that, I do believe it is possible to pass the QLTS without signing up for any such courses, but it will definitely be harder, and hopefully you will (unlike me) have more than just two weeks of preparation time.

The MCT

For the MCT, the following subjects are covered by the exams:

  • Contract Law
  • Tort Law
  • Criminal Law
  • Land Law
  • Equity & Trusts
  • Public Law
  • Business Law
  • Tax Law
  • Human Rights Law
  • Solicitors’ Accounts
  • Professional Conduct
  • English Legal System

For my study schedule, I essentially spent one entire day each for subjects I was already familiar with (e.g. contract law, tort law) while I spent two days each on subjects that were more alien to me (e.g. EU law, land law). I then did the Kaplan sample questions (available from the website) and revised heavily in the last three days leading up to the test date. As I was seriously pressed for time, I had taken a gamble and skipped out on fully studying some subjects (e.g. Human Rights Law, English Legal System), but I found that doing so did not really hurt me by much in the exams. If your goal is simply to pass and you have insufficient preparation time, my advice would be to focus on the subjects that you are already familiar with and do a good job with those so that you can be assured that you will get the questions on those subjects correct, but ultimately you will need to exercise your own discretion on what level of preparation you will be comfortable with. You should also note that the MCT is only concerned with general principles of law, so there is no need to memorise case names, section numbers, etc.

For the exam itself, time management is essential. You should spare only one to two minutes for each question – if you truly don’t know the answer, choose any one option and move on to the next question. There are various exam techniques that one can apply here with regard to multiple-choice questions, e.g. process of elimination. The MCT is split up into two parts with a small break in between – bring food and water to refuel during that break. For my experience, I had finished the first part at the very last second because I had spent too much time with the difficult questions, in particular the ones that require calculations like tax law. The second part was much easier for me as I had become accustomed to the stress and I stopped fretting about getting the correct answer for each question. It is much more important to answer as many questions as you can than to assure yourself that you’ve got the right answer to the question right in front of you – remember that you only need to achieve the passing mark.

The OSCE – General

For the OSCE, the following subjects are covered:

  • Civil Litigation
  • Criminal Litigation
  • Business Law
  • Property Practice
  • Probate Practice
  • Professional Conduct
  • Accounts
  • Tax Law

For my study schedule, I spent two days of studying each for civil and criminal litigation, business law, property practice, and probate practice. I spent about a day or two revising some basic principles from the subjects I had studied for the MCT, such as contract law, tort law, and criminal law, as a basic grasp of those principles are required for the OSCE. I then spent the remainder of my time practicing mock exam papers. The OSCE is much more practical in nature, so it is critically important for you to practice both the written and oral components of the OSCE – if you can, try to form a study group with other candidates in order to practice the required skills. I will go into more detail on what I did to prepare in the later sections below.

For logistics, I would recommend staying somewhere near King’s Cross, as there are multiple transport options there to get to the two exam venues. For myself, I stayed in Holborn, which was not a bad option as well. I would also recommend bringing some food and water to the exam hall, as the exam timings are not particularly concerned with the usual time for lunch or dinner. Although you will need to stash all of your belongings in a locker, there will be some table space to put some food and drinks to consume during the breaks. Also, remember to bring your passport – you will need to exchange it for a candidate pass.

The OSCE – Part I

Part I of the OSCE is all about oral skills, and tests three components: the client interview, the attendance note, and advocacy/presentation.

Qlts Qualification

Client Interview

This part of the exam requires you to interview a “client” who has come to you for some legal advice, while taking notes of all information given to you and all legal advice you may have given to the client. You will be given 10 minutes to prepare based on an information pack – I used this time to formulate the questions I needed to ask the client based on the potential issues that arose from the facts. The focus here should be to gather the required information from the client in the 25 minutes allotted; otherwise, whatever legal advice you can give will inevitably be incomplete. I also used the 10 minutes of preparation time to quickly write a skeleton attendance note (see below for the structure), which most certainly saved me a lot of time.

For the interview itself, I asked general questions at the beginning and tried my best to show as much empathy as possible (as the client might very well be upset at his or her situation). I then focused on specific questions that dealt with the legal issues that might arise. I also used as little legalese as possible and focused on advising how the client might get to his or her desired outcome, even if it may be difficult on the facts. There’s no value in telling the client that nothing can be done and you’re of no help at all.

When taking the client interview notes, be sure to write as legibly and as neatly as you can, because you can simply append the client interview notes (label it “Appendix 1” at the top right hand corner) to the attendance note so that you won’t have to re-draft any of the facts and issues identified during the interview or any legal advice you may have given during the interview itself. Don’t hesitate to tell the client that you will need a moment or two to write down what was just talked about – it’s more important to write down the information you got than to hear all of the information you could possibly extract from the client.

Attendance Note

At the end of the client interview, you will be given 25 minutes to write an attendance note, which should include the following information:

  • Preliminary information, such as the date, name of client, the subject of the interview, and time engaged
  • The substantive sections, which should have: (a) an introduction; (b) the basic facts; (c) the client’s concerns and issues identified; (d) the legal advice (the most important section); and (e) the next steps to take.
  • A signature at the end (e.g. “John Smith, Junior Solicitor”)

I also appended my client interview notes as “Appendix 1” and made liberal references to it in the various sections (especially the sections on the basic facts and the client’s concerns).

I found this part of the exams to be rather challenging, simply because of the time pressure and hand fatigue from writing so much. I had definitely benefited from practising the actual writing of an attendance note – I wrote about three practice attendance notes under similar time pressures before stepping into the exam hall. If you would like me to send you some sample attendance notes, just drop me a message and I’ll be happy to oblige.

Advocacy/Presentation

You will be asked to give an oral presentation or advocacy piece in front of a 'client' or 'judge'. What is critical here is practice – there’s no way around it. You just have to find someone to act as a judge or a client to present either an advocacy piece or an analysis of a set of legal issues.

Advocacy is generally only applicable for civil and criminal litigation, and due to the fact that you’re given only 15 minutes to present (45 minutes to prepare), the questions are likely to be on interlocutory or summary matters that won’t require a full blown trial. For civil litigation, I practised a lot of moots on interlocutory applications (e.g. summary judgment, judgment in default, striking out, interim payment, etc), while for criminal litigation, I practised a lot on bail applications and mitigation pleas. It goes without saying that memorisation of the essential elements of each application is necessary. I spent my 45 minutes of preparation time reading the materials (which included the parties’ pleadings and witness statements) and made a bullet point script, and made a note of what is most likely going to determine the application, as the judge may (as mine did) wish to skip to those parts at the outset. For the actual advocacy, try to speak calmly and in a measured tone – I spoke rather slowly but I still only spent about 10-12 minutes going through the entire application and the judge’s questions, so don’t worry too much about the time.

The oral presentation will usually feature in business law and property/probate practice. This part will require a lot of memorisation of the law, because you will not be given any opportunity to research. What I did was to pick out various topics that I felt were likely to be tested and memorised every single thing about it. For example, in business law, I memorised whatever I could on interests in transactions, substantial property transactions, loans to directors, share transfers, insolvency and security interests, etc, while for property practice, I memorised whatever I could on the assignment of leases, sale of part of a property, security of tenure, etc. It is impossible to predict what will eventually come out, so it’s really about making an educated guess about what is possible in a 15 minute presentation and focusing on those topics.

The OSCE – Part II

Part II of the OSCE is all about skills at the desk, i.e. drafting, research, and writing. You will be given access to both Westlaw and Lexis, but in my experience only Lexis is required.

Drafting

You will be asked to draft something in 45 minutes that you have likely never seen before, e.g. filling in a certain form or following a certain template. For business law, it may be board minutes or draft resolutions; for civil/criminal litigation, it may be a claim form or draft order; and for property/probate practice, it may be to amend a will or filling in a tax form. I was sometimes given precedents to work from as a base, but they were never exactly on point and I remember having to synthesise various precedents into something that worked for the issue at hand. If no precedents are given, the Forms and Precedents section on Lexis may prove useful, but I wouldn’t recommend spending more than five to ten minutes locating one – if you can’t, just give up and come up with something on your own.

What really helped me here was the QLTS Advantage, as it provided several exercises with model answers to work from. I had practised writing certain things such as drafting board minutes and resolutions and claim forms, so it wasn’t entirely alien to me when I went into the exam hall. I was also fairly familiar with locating precedents on Lexis, so I could quickly locate something useful and put it into my draft. If you don’t have or want to sign up with a course provider, you can attempt the Kaplan sample materials, which should give you a flavour of what kind of questions you may face and precedents you may need from Lexis.

Research

You will be asked to complete a research task in 60 minutes. It is critical here to practise using Lexis. If you’re with a firm that has access to Lexis, then you should definitely practise on a daily basis. If you’re not familiar with Lexis, go through the Lexis tutorials here: http://help.lexisnexis.com/tabula-rasa/rosetta/gh_tutorial-topic?lbu=GB&locale=en_GB&audience=legal. Also, try to be familiar with Boolean search terms – I found most of my answers simply by entering key words and the “w/3” connector.

The starting point (as many have said) should be the Halsbury’s Laws of England. In most scenarios, you will be able to find the answer there. However, there might be an obscure question of law that Halsbury’s won’t be able to assist. I have compiled here a list of the most useful resources you may resort to during the exam; it may be useful for you to memorise them and how to navigate there in Lexis:

  • General: Halsbury’s Laws of England, Encyclopaedia of Forms and Precedents
  • Criminal Litigation: Blackstone's Criminal Practice
  • Civil Litigation: Atkin's Court Forms, The Green Book, Butterworths Civil Court Practice
  • Property: Butterworths Property Law Service, Harvey & Redman's Law of Landlord and Tenant, Ross Commercial Property Precedents
  • Probate: BWPAS Probate Precedents, Tristan & Coote's Probate Precedents, Tristan & Coote's Probate Service, Tolley's Inheritance Tax
  • Business: BCLS Corporate Precedents, Butterworths Corporate Service

For the answer itself, you will be given two sections to fill in, “Advice to Give to the Client” and “Legal Reasoning Mentioning any Key Sources or Authorities”. What I did was to give, in the first section, both a short answer (in layman’s language) in bullet point form, and a long answer with all the legal reasoning and references (including case names and statutory provisions). Though the second section is named “Legal Reasoning”, I had used it entirely for the purpose of providing my sources of information by copying and pasting the “Location” information at the bottom right hand corner of Lexis. I found this to be a much better way of organising the information, and I did not seem to be hurt by it. If you would like me to send you some sample research answers, feel free to just ask by dropping me a message.

Writing

You will be asked to write a letter of advice to the client in 30 minutes. The time pressure here is immense – you will need to have the law at your fingertips as there is simply no time to do more than five minutes of research if you absolutely don’t know the answer. I had beforehand practiced drafting standard letters of advice, so I had walked into the exam hall with a template in my head that needed just some minor tweaking.

At the exam itself, what I did first was to draft the beginning and the end, as you will be marked down severely if you don’t have a complete letter to the client. It’s absolutely not worth it to lose marks simply by failing to tell the client that you’re contactable for further questions or failing to sign the letter off with the partner’s name. Also, don’t panic if you don’t know the answer to every part of the question posed to you. I remember not knowing the answer to one particular part of the question in one of the writing tests, but I had no time to find the answer, so I simply went with one (probably incorrect) position and wrote an intelligible (but not necessarily intelligent) piece of advice to the client.


And that’s it! I hope this has been helpful if you’re looking to take on the QLTS. If you’re of two minds on whether you want to take it, you should note that the QLTS is soon going to be replaced by a new “super exam” called the Solicitors Qualification Exam (SQE), which is a whole new unknown world, so I would definitely recommend taking the QLTS as soon as you can. I also hope that you can set aside sufficient time to prepare for the exams; I had most certainly sacrificed a certain amount of my lifespan preparing for it in just four weeks total, though it is demonstrably possible. As Leonard Bernstein said, “to achieve great things, two things are needed; a plan, and not quite enough time.”

This article is for information purposes only.

ORIGINAL ARTICLE PUBLISHED 14 JUNE 2020.



UPDATE - 28 OCTOBER 2020:

The decision from the LSB came in and no extensions or changes were proposed.

The full decision can be found here: https://www.legalservicesboard.org.uk/wp-content/uploads/2020/10/20201027-Decision-Notice-SQE.pdf


____________________________________________________________

UPDATE - 25 AUGUST 2020:

The initial challenge of the SRA’s policy, surrounding its unfair and unequal treatment of LPC graduates, bizarre QLTS deadlines and the refusal to accept the impact of the global pandemic on qualification in England, was unsuccessful despite lengthy correspondence with the SRA’s Head of Legal Policy.

However, the Legal Services Board has agreed to admit our representation against the application made by the SRA on 31 July 2020 for the final approval of the SQE.

We hope that our representation, together with the representation made on 21 August 2020 urging the LSB not to grant the SRA’s application, will receive positive consideration.

____________________________________________________________

UPDATE - 20 JUNE 2020:

It has come to my attention that the current wait times for admission overseas have now been delayed for up to a year. One of those jurisdictions is New York where, from the moment of application for admission, the processing takes between 6-12 months due to the pandemic, therefore, disadvantaging MCT-exempt individuals who were unable to attempt the Bar exam in 2020. It will be impossible for those taking the Bar in February 2021 to be sworn in before the current SRA deadline of 31/08/2021 (if MCT-exempt). Furthermore, considering the situation in the US at the moment and the uncontrollable spread of the virus, MCT-takers might be affected as well.

____________________________________________________________

Background

Qlts

The QLTS is an exam for foreign lawyers wanting to cross qualify in England. It is administered by Kaplan and is made up of two parts: MCT (Black letter law) and OSCE (Practice).

Most aspiring solicitors have three options to qualify in England; options that all of us see at the law fairs and networking events every time that we attend one. These are:

a) the traditional training contract which, for many, is impossible to secure due to very high demand and not enough available places;

b) equivalent means for which one must do specific work under the direction of another solicitor for 2 years, and

c) pass NY or CA Bar followed by the QLTS to become dual-qualified.

Equivalent means route is difficult due to the high burden of proof and the fact that most who did not obtain a training contract are mature students who, like me, hold the most senior legal position in their company and not working under the direction of a solicitor. This is why the QLTS is the only option for many of us. Option, which due to the delays caused by the pandemic and the arbitrary policy of the SRA, is being more difficult to achieve.


My story

I am an LLB and LPC graduate. I intended to pass the New York Bar in July 2020, QLTS in November 2020 and qualify in England and Wales by January 2021. I started my bar prep with Barbri in September 2019 with 200 other participants, many of whom intended to qualify in England.

Due to the global pandemic, the NY Bar exam was postponed to February 2021. Bearing in mind the introduction of the SQE in September 2021, I suspected that there may be issues passing the QLTS in time. This situation led me to my own little investigation into deadlines.

MCT-exempt

The last MCT will be administered in the summer of 2021. Those who attempt it then will have an additional year (until summer 2022) to pass OSCE (“Transition Period”). However, the Transition Period DOES NOT apply to those exempt from the MCT requirement such as LPC graduates. MCT-exempt applicants have to complete their OSCE in the summer of 2021, the latest, which leaves us with two sittings in November 2020 and summer 2021. Those MCT-exempt individuals MUST apply for admission by 31 August 2021 and in order to do so, one must be fully qualified and admitted overseas.

This creates an issue for those of us who are unable to pass the Bar in 2020 due to the pandemic. This means that our last chance to qualify in England will be the bar exam (for NY and CA) in February 2021. If we fail or if due to the pandemic the exam is postponed till July 2021, we will be unable to qualify in England at all as our results won’t come in before 31 August 2021, therefore we will not be qualified foreign lawyers before the deadline for admission application in England. This means that we will be out of pocket for the cost of the LPC, Bar preparation course, and the OSCE exam (this is over £40,000).

Those exempt from the MCT requirement are already put at a disadvantage as we are not allowed to benefit from the Transition Period and have only until 31 August 2021 to apply for admission. However, even the MCT-takers are in trouble as due to the delays and cancellations of the exams abroad, they do not have an opportunity to prepare for the MCT unless they study for both, overseas bar examination and the MCT, at the same time which is not feasible because most students have full-time jobs and it would be very difficult, if not impossible, to prepare for 2 life-changing exams in two completely different jurisdictions all whilst going to work, vulnerable, shielding and taking care of other family-related obligations. Furthermore, studying for 2 exams is unlikely to result in success in either one which will increase the already challenging time commitment and financial and mental pressure.

This information is not easily accessible to the applicants and the QLTS providers do not seem to be aware of this either and keep advising students that they can apply for admission at any time after passing QLTS. Having spoken to a few of them, despite numerous meetings and guidance from the SRA, I was informed that all were informed of the long stop rules being given to students but there was no mention that LPC students would not be treated the same as all the rest of the applicants. For example, I decided to have a one-year break between completing the LPC in 2018 and starting the NY Bar prep course. Had I known that there is a deadline, I would not have done that. Only in my own Barbri course group, there are at least 25 affected individuals who were not aware of this situation.

SRAChallenge

In the light of my findings, on 16 May 2020, I have written a formal letter to the SRA (CC: Kaplan and the Law Society) challenging the current policy. I have asked for a general extension of the QLTS due to the pandemic and in the alternative, to allow MCT-exempt individuals to be treated equally and fairly and benefit from the same Transition Period allowed to the MCT-takers.

Qlts Dual Qualification

Three weeks later, I received a letter from the SRA. Unfortunately, they are unwilling to consider a policy review, in respect of the QLTS extension and those exempt from the MCT negatively impacted by the unavailability of the Transition Period, due to the global pandemic and the inequality of the current policy respectively.

The SRA proposed that the MCT-exempt individuals apply for the MCT anyway in order to benefit from the Transition Period. This idea is unreasonable as it would result in additional studying and expense from which we are exempt under the SRA’s own policy. Such a move should not be necessary under any circumstances.

The SRA has stated that they allowed the MCT-takers to benefit from the Transition Period because they made a “financial commitment” by paying the exam fee (approx. £700). I have completed the LPC with a view of passing the NY bar and subsequently completing the QLTS. This will cost me over £40,000 in total and I consider this a financial commitment to the QLTS even without paying the £700 for the MCT exam specifically. Furthermore, I believe that by applying for the MCT exemption we are showing our commitment to the QLTS - it is not something that we would have done without having the intention to go down that route.

The whole reason that the SQE was set up was to provide access to legal qualification to all and therefore it is not reasonable to now be disadvantaging one group over another. According to the SRA, the introduction of the SQE meant to ensure that all trainee solicitors, no matter which route they take, have the same opportunities and to ensure consistency and high standards across the board and silencing the notion that one route to qualification is better than another. The SRA also said that the SQE will make the law profession more accessible by lowering the cost of study (in comparison with the GDL and LPC.) In reality, not only not every applicant is treated the same and the only proposal by the SRA to cure that lack of equality involved spending more money by taking an exam from which many are exempt.

The extension does not have to result in the postponement of the SQE. I understand that the SRA has an obligation to roll out the SQE as soon as possible, which I note has not yet been signed off by the LSB, but there is no reason why both can’t run consecutively for a year especially as the SRA already planned for the OSCE to be available at the same time as the SQE for the MCT-takers. Furthermore, OSCE exams will continue under the current policy until 2022 for those that completed the MCT, therefore, those exempt from the MCT should be allowed to attend also. Such an allowance will not result in any additional effort for Kaplan/SRA. On the contrary, it will have commercial advantages to both, as there will be more OSCE applicants spending almost £4,000 each for an additional year.

I have further replied to the SRA setting out those points on 15 June 2020 and I currently await their response. Kaplan, the Law Society, Barbri, and leading QLTS course providers have been made aware of this situation.

Conclusion

QLTS route has been established to provide international lawyers with the ability to qualify in England and Wales. This has been a viable option to qualify for years and many students embarked on this path already just to face delays and barriers during the process due to the pandemic.

At this difficult time, when the exams and qualifications around the world are being postponed, there is uncertainty surrounding traveling restrictions and the fact that the NY is prioritising their own students, it would seem reasonable for the SRA to prioritise us - those who want to qualify here and those who spent a lot of money on the LPC in England already, to consider an extension of that route to qualification or at least to ensure that everyone has the same chance of success and ensuring that their regulation applies to MCT-exempted individuals.

Let’s keep our fingers crossed that the SRA listens to our pleadings and makes the right decision.