Today's Financial Services Authority decision notice against Arch Financial Products (AFP), Robin Farrell, AFP's chief executive, and Robert Addison, a senior partner and former compliance officer at AFP, reads like a how to guide of how not to run an investment.
In the FSA's opinion, - and all the other parties are disputing the charges - AFP pursued an investment strategy which resulted in significant liquidity risks for funds that were advertised as "low risk" or "cautious".
Further, the FSA believes that AFP and Farrell failed to ensure that the funds aimed to provide a prudent spread of risk.
Also, AFP was in a position of trust and needed to demonstrate fair management of conflicts of interest - in the FSA's opinion, AFP failed to do so, not least in the covert share sale that netted Farrell £492,000 personally.
Given their roles, managing conflicts of interest fairly was a key responsibility of both Farrell and Addison, and, in the FSA's opinion, their failings in this regard were "reckless and therefore demonstrated a lack of integrity".
AFP and Addison also adopted an informal, ad hoc approach to compliance monitoring with insufficient recording of the monitoring that was undertaken, the FSA said.
It is difficult to know how exactly advisers who recommended Arch Cru could be expected to have known about all of this.
Advisers are not private detectives. But according to the FSA they should have found out information that was even kept hidden from non-AFP directors of the Guernsey fund range.
But yesterday's release of the FSA's Arch Cru redress scheme shows the regulator still intends to pursue IFAs - and expects at least 100 to go to the wall as a result.
Perhaps advisers should start petitioning the FSA for clearer guidelines about exactly how much due diligence they are expected to do on each investment decision - what depth and breadth in specific terms.
And then ask how they will get consumers to pay for this mammoth piece of work.
Six hours for a client report
700,000 transfers in 12 months
104 delegates attended
'Benefit from healthy cash levels'
Could be two months to complete payment