Whilst R3 agrees that a revision of SIP 14 is necessary, we believe the current draft is too broad and lacks clarity and cohesion. The draft tries to accomplish too much and, as a result, contains ambiguous language and sometimes repeats existing insolvency rules. R3 proposes that the SIP be split into two separate SIPs to provide clearer, more practical guidance for IPs. Furthermore, R3 is firm in its belief that SIPs are intended for IPs and their staff, not for external stakeholders. Information for other stakeholders should be provided through different channels, such as the R3 and RPB websites.