Before proceeding to assess the extent of a complainant's financial loss, a firm will usually have completed the following stages:
(1) gathering all relevant facts and information;
(2) making a fair and objective assessment whether it has failed to comply with a relevant duty owed to the complainant; and
(3) assessing whether any failure of duty by it was in the circumstances a material failure in the sense that if it had not occurred the complainant would have been likely to have acted differently.