ramping and fee rorting from bnb on bbp, page-6

Is the issue one of

a) Poor advice / management
- was it poor at the time it was given or only in hindsight?

b) Asset aquisition / churn to boost fees
- can the board mandate a more conservative approach (put them on a tight leash)?

c) Fees are exessive for the transactions done
- aren't there laws which say that transaction fees must reflect the cost of the transaction? I know this applies to retail banks (but is not well enforced).