What about an FI without CPL TK?
There are a lot of FIs without CPL TK who enjoy grandfather status and have full FI privileges; not to be confused with LAPL FIs who are limited to giving instruction for the LAPL only. As there is nothing to sign in a LAPL they cannot get 945 privileges. However; if they are also a CRI then they can get 945 privileges. Another load of nonsense.