What's wrong with fronting
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Under the section on good repute and fitness, the senior TC's Statutory Guidance and Statutory Directions spell out the problem with fronting: it deprives a TO of the opportunity to oversee an operator.
Fronting is aggravated and is much more serious when it is apparent that the entity hiding behind the legitimate front would be unlikely to obtain or would be debarred from holding their own 0-licence. The upper tribunal has given clear guidance that evidence of fronting can, on its own, provide justification for deciding that the operator being used as a front has lost its good repute. • More information: gov.uk/government/publications/senior-trafficcommissioners-statutory-guidance-and-statutory-directions