IMO, it's much more fundamental.
If a creditor reasonably believes that the keeper was the driver when they start to pursue the alleged debt then it's an abuse of process to issue a spurious PCN addressed to the keeper dressed up in PoFA-like references, but not PoFA itself, to embroil the keeper in their claim. Even worse, possibly to go to IAS with a claim against the keeper and then to have a miraculous epiphany on the road to court such that their claim is transformed from one against the driver to one against the keeper-cum-driver especially if they offer any evidence obtained from the keeper post issuing their PCN.
Clean hands, my a**e.