Alison didn’t go looking for trouble. Trouble came looking for her.
When she agreed to become her firm’s COFA, it felt like the sensible, grown-up thing to do. She was a salaried partner at a busy regional firm, respected, calm under pressure, and someone the board trusted. She wasn’t a finance specialist, but that was the point. The firm had an experienced finance director who was chartered, a capable cashiering team, and a modern accounts system. Alison’s job, as she saw it, was governance: to make sure the right people were in the right seats, the right processes were in place, and the right questions were asked.
And she did ask questions.
Every month, a reconciliation pack landed in her inbox a few days after month-end. It was neatly presented: client ledger, bank balances, suspense items, explanations for residuals, a short narrative from the finance director confirming everything reconciled and any movements were understood. Alison would read it, skim the notes, and sign. Occasionally she’d query something that looked odd, like an old client balance, a delay in transferring interest, a suspense item hanging around. The finance team would come back quickly with an answer.
It all felt reasonable. Responsible, even. She wasn’t pretending to be an accountant. She was relying on finance-qualified professionals to do finance work.
In fact, she took comfort from it. This looked like the right division of labour. Finance produced the figures. Alison provided oversight. The managing partner got a one-page confirmation that the firm was compliant.
The first cracks didn’t look too alarming. It started with a change in personnel. The long-standing finance director left. There was a handover period, then an interim, then a replacement who was confident and fast-moving. The cashiering team changed too: one senior cashier went off sick, another left, a new assistant joined. None of this was dramatic. It was the ordinary churn of professional life.
The reconciliation pack kept arriving.
If anything, the new finance head made it look slicker. The narrative was tighter. The explanations were shorter. The spreadsheets were colour-coded. Alison liked that. She liked the sense that the firm had grown up, become more polished, more controlled.
She didn’t notice that what had changed wasn’t the formatting. It was the substance.
Items that used to be broken down were now “netted off”. Old residual balances were shown as “being cleared” without dates. There were a few bigger suspense movements that were explained as “timing differences” and “banking delays”. Alison raised an eyebrow at one of them and got a brisk answer: the money had moved, it just hadn’t hit the ledger yet. The explanation sounded plausible. It came from someone finance-qualified. The system was complicated. Everyone was busy. Alison signed.
The truth is, Alison didn’t have the skills to investigate the figures. Not properly. She didn’t understand legal cashiering at a granular level. She couldn’t interrogate a ledger and trace a balance through to a bank statement with confidence. She couldn’t spot the tell-tale signs of a concealment or a workaround, because she didn’t know what the normal pattern should be.
And because the pack was always there, always professional, always reconciled, she didn’t feel the need to develop those skills. That’s the trap. The more competent the finance team appears, the more tempting it is to outsource not just the work, but the understanding.
A year passed like that.
Then the reporting accountant came in.
It was the usual annual visit: a few questions, a few sample checks, the polite professional rhythm of an exercise everyone treats as routine until it isn’t. Alison didn’t worry. The firm had always had clean accountants’ reports.
Two weeks later she received an email asking for a call.
The reporting accountant’s tone was careful, as if he was trying not to alarm her while knowing he couldn’t avoid it.
There was a discrepancy in the client account reconciliations. Not a small one. A figure that didn’t tie. A reconciliation statement that, on a proper drill-down, didn’t reconcile at all.
Alison’s first reaction was simple disbelief. She opened the packs she’d signed. They were all there. Month after month. Neat. Confident. “Reconciled”.
The accountant walked her through it slowly. The reconciliation statements relied on adjustments that weren’t supported. There were balances that had been carried forward without proper resolution. Certain transfers had been recorded in the ledger as if they had happened, when the bank position didn’t match at the time. The difference wasn’t huge in the grand scheme of the firm’s turnover, but it was enough to be a breach. Enough to qualify the report.
Enough to trigger a self-report to the SRA.
Alison sat at her desk after the call, staring at the word “qualified” as if it was written in another language. She felt physically cold.
The board meeting that followed was grim. No one shouted at Alison. In a way, that made it worse. They were focused on damage limitation, remediation, and messaging. They asked what had happened. Alison didn’t know. That was the point. She had signed the statements, but she couldn’t explain the numbers.
The new finance head became defensive. The interim finance period was blamed. The system was blamed. Staffing was blamed. The finance team produced a flurry of spreadsheets and action plans. Someone suggested an external consultant to “sense-check” the reconciliations going forward. Everyone nodded.
And then the SRA wrote.
The subsequent investigation felt like an entire chapter of her life.
It started with information requests. Polite, formal, oddly impersonal letters asking for documents that now carried a new significance: reconciliation statements, policies, training records, evidence of oversight, minutes, audit trails. Each request implied a question Alison couldn’t un-hear: what were you doing as COFA?
Alison began to dread the ping of her inbox. Her sleep changed. She’d wake at 3am, brain replaying the same loop: I signed it. I signed it. I signed it.
The firm did what it could. They reassured her. They hired support. They fixed the processes. They introduced new checks. They documented everything. On paper, the firm became better governed than it had ever been.
But none of that changed the personal reality: Alison was the named officer.
Eighteen months passed. In the end, the SRA took no further action. The breach had been real but was remediated. There was no evidence of dishonesty. The firm had cooperated. Improvements were made. The regulator moved on.
Alison didn’t, not immediately.
She had spent all this time living with the knowledge that her professional life could unravel because she’d relied on people who, on the face of it, were exactly the people she should have relied on. She had done what most sensible leaders do: delegate to experts.
The hard lesson was this: you can delegate tasks, but you cannot delegate accountability. And if you don’t understand the numbers you’re signing, you’re just providing a signature when you should be providing oversight.
That doesn’t mean a COFA must be an accountant. It does mean a COFA needs enough technical confidence to ask the right questions, test the answers, and spot explanations that don’t add up. It means being able to drill into a reconciliation pack and follow the thread until you’re satisfied, not until you’re reassured.
“The finance team told me everything was fine” is not a defence. It’s an admission that you didn’t have the skill to do the role properly.
If you want to build confidence in your role, we’re running an in-person COFA masterclass shortly. It’s practical, example-led, and designed to help you understand what the SRA expects, delivered by those wrote the Accounts Rules and investigated firms when they got it wrong.
