On 6 October 2005 the Bar Council of The New South Wales Bar Association noted that it was unable to make a determination under s38FC and s38FE of the Legal Profession Act 1987 with respect to the notification made by Bryan Francis Rowe.

The Bar Council further noted that an indefinite statutory suspension of the practising certificate of Bryan Francis Rowe would follow in accordance with the provisions of s38FH of the Legal Profession Act 1987 from midnight on Saturday, 29 October 2005.

On 17 January 2006 the Acting Legal Services Commissioner determined that Bryan Francis Rowe is a fit and proper person to hold a local practising certificate but that it is appropriate to impose financial management conditions on Rowe's local practising certificate and on any local practising certificate held by Bryan Francis Rowe with respect to any period up to and including 30 June 2010.

On 6 February 2006 the Bar Council issued a local practising certificate to Bryan Francis Rowe with conditions attached, being those determined by the Acting Legal Services Commissioner.