they always did....
the TIO guidelines always ensured only the big players could afford to stay in the industry
that is why all the small players vanished and the industry consolidated into a dozen major players from the 220+ players that were in it in those days.
if you didn't get a complaint against you then you were fine but the moment you did you got the pleasure of paying for the big players lack of customer service to the tune of many thousands of dollars in some cases for 1 complaint justified or not....
small / medium players simply couldnt take the gamble
luckily i never had to face it but i know many that did and lost everything...

