MARA decision: “all clients” dealt with by RMAs?

If an RMA's website advertised that "your case will be represented and advocated only by [an RMA] throughout the entire application process", but a client was not dealt with by an RMA, was that advertisement, combined with other factors, misleading even if the non-RMA dealing with that client was located overseas?

To avoid doubt, we are not expressing an opinion on the conduct of the practitioner or anyone else nor on the OMARA’s decision. This article is a mere extract of only some aspects of a decision and should not be interpreted in any other way.

The OMARA answered as follows:

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