¶ 1 This is the attorney’s third time before this Court. Munson was suspended from the practice of law from December 12, 1988 through January 4, 1990 (Munson I)1 for two counts of misrepresentation and neglect. The Bar Association filed a complaint against the attorney in 1992. The allegations were that the attorney: 1) misrepresented the nature of business transactions to a bank inducing the institution to provide immediate funds on a check drawn on an account at another bank; and 2) presented checks totaling approximately $55,000.00 knowing that there were insufficient funds on deposit in the accounts upon which they were drawn. Following the hearings in the consolidated causes, the trial panel recommend a suspen*98sion of two years and one day. Thereafter, Munson filed an application, pursuant to Rule 8.1, Rules Governing Disciplinary Proceedings, 5 O.S.1991, Ch. 1, App. 1-A,2 requesting that he be allowed to resign his membership in the Bar Association and relinquish his right to practice law. We consolidated the complaint heard by the trial panel with another complaint filed on January 8, 1993. The second complaint alleged the mishandling of an additional $50,000.00 and failure to respond. The Court approved the resignation on February 16, 1993 ordering Mun-son to comply with Rule 9.1, Rules Governing Disciplinary Proceedings, 5 O.S.1991, Ch. 1, App. 1-A3 and to pay the costs of the proceeding within a reasonable time from the date of the order (Munson II ).4 Today, we address Munson’s petition for reinstatement.
¶ 2 Upon a de novo review,5 we determine that the attorney did not present clear and convincing evidence that, if readmitted, his conduct would conform to the high standards required of a member of the Bar Association.6 Therefore, we deny reinstatement and impose the costs of the proceeding in the amount of $1,705.47.7 Our decision is sup*99ported by evidence of the attorney’s unauthorized practice of law during his initial suspension in Munson I along with his lack of candor concerning the factors leading up to his 1993 resignation and by uncertainty concerning his competency to practice law raised by the lack of strict compliance with the rules governing suspension and reinstatement proceedings.
FACTS RELEVANT TO REINSTATEMENT PROCEEDINGS
¶ 3 Munson was admitted to the practice of law on August 17,1973. Fifteen years later, we suspended the attorney for one year on two counts of misrepresentation and neglect. Just three years later, after the trial panel recommended a suspension of two years and one day, we approved Munson’s application for resignation pending disciplinary proceedings.
¶4 The transactions leading to the attorney’s resignation grew out of two consolidated complaints. SCBD No. 3840 arose from transactions involving an attempt by Munson and the Vammen family to set up an integrated farming operating. The Vammens loaned the attorney $62,000.00 in conjunction with the business venture. When the attorney was unsuccessful in getting further financing, the Vammens requested that their monies be returned.
¶ 5 In an attempt to pay one of the family members their portion of the funds, the attorney drew a check for $46,000.00 on his trust account when the balance on the date of the check’s issuance was $187.75. Two weeks later, the attorney again attempted to pay the same family members. At that time, while in Jay, Oklahoma, Munson represented to a bank officer of the Delaware County Bank that he had closed a real estate transaction for clients purchasing land from the Vammens. Munson advised the officer that he needed to deposit a check for $48,000.00 on a Tahlequah account to an account in the Delaware County Bank and then have a wire sent from the Jay bank to the Vammens’ bank in Texarkana for $46,000.00. Based on the officer’s prior business dealings with Munson and the representations involving the land sale, the wire transfer was approved. When the check was deposited in the Delaware County Bank, no such real estate transaction had occurred and the balance in the Tahlequah bank account was in the negative. The Delaware County Bank did not receive all of its funds until after having filed suit against the attorney and engaging in collection efforts on the summary judgment entered in the cause.
¶ 6 Another Vammen family member sought repayment of her portion of the investment. Munson wrote a check on the Delaware County Bank trust account for $6,851.33. The check was dishonored. When the check was issued, the account contained only $956.47.
¶ 7 The trial panel conducted a hearing in this matter on December 11, 1992. In January of the next year, it issued a report which recommended that the attorney be suspended for a period of two years and one day.
¶ 8 While SCBD No. 3840 was pending, a complaint was filed in SCBD No. 3894 alleging three counts of misconduct. We consoli*100dated this complaint with the prior one for purposes of considering the attorney’s application for resignation. The first two counts of the consolidated case involved Munson’s having taken a check for $25,972.42 from a client, Betts Gordon (Gordon), “for safe keeping.” The representation involved a probate matter. Shortly after obtaining the check, the attorney cashed the same and allegedly placed the funds in a zipper bag in an office safe. When several months passed and nothing occurred in the probate case, Gordon’s sons sought a return of the monies. They filed a complaint with the Bar Association and Munson agreed to allow a Bar Association representative to come to his office and verify that the funds were being held there. When the Bar Association investigator arrived, Munson refused to allow the representative to count the monies. Several days later, the attorney deposited $25,972.42 in Gordon’s account in Boatman’s Bank in Tulsa. Initially, the Bar Association did not receive a response to the complaint filed in the cause. Munson appeared only upon a subpoena having issued. The attorney testified that he had mailed a response to the Bar Association from Tahlequah on November 28, 1992. Nevertheless, when the Bar Association received the response, it carried an Oklahoma City postmark of December 4th.
¶ 9 The third count arose out of the attorney having been appointed executor in the estate of David E. Deatherage on September 19th, 1989. Evidently, the attorney took this appointment during the time of his suspension in Munson I.8 In May of the following year, Munson opened an account in the First State Bank of Tahlequah in the estate’s name. When the deceased’s wife contacted him about social security benefits she was receiving for her minor daughter, the attorney suggested that she leave the monies with him until he could gain some guidance from the Social Security Administration. On September 21, 1992 the wife wrote Munson a check for $22,505.37. He deposited the check into the estate account which then contained approximately $1,885.83. Four days later, a check cleared the account dated September 14th in the amount of $17,184.58. The check was made payable to one of Mun-son’s other clients as repayment for monies he was holding on her behalf.
¶ 10 The attorney filed his petition for reinstatement on August 3, 2009 supplementing it on the next day with affidavits of court clerks inadvertently left out of the original filing. The hearing on reinstatement was held before the trial panel on November 18, 2009. The trial panel issued its report on January 5, 2010 determining that Munson had not met the burden of proof for reinstatement and recommending that reinstatement be denied and costs be imposed. On the same day, the Bar Association filed an application for the assessment of costs in the amount of $1,705.47. The order setting a briefing schedule issued on January 6, 2010. Munson was given an extension to February 3rd for the filing of his brief in chief. The briefing cycle was completed on March 3, 2010 with the filing of the attorney’s supplemental answer brief.
JURISDICTION, STANDARD OF REVIEW, AND BURDEN OF PROOF
¶ 11 It is this Court’s nondelegable, constitutional responsibility to regulate both the practice and the ethics, licensure, and discipline of the practitioners of the law. The duty is vested solely in this department of government.9 Our determinations are made de novo.10 Although given great weight,11 neither the findings of fact of the *101trial panel nor its view of the evidence or the credibility of witnesses bind this Court. The recommendation is merely advisory.12 We are bound neither by its findings nor its assessments as to the weight or credibility of the evidence.13 A thorough and complete exploration of all relevant facts is mandatory in consideration of matters to regulate the practice of law and legal practitioners.14 Attorneys suspended for disciplinary reasons will not automatically be reinstated on a pri-ma facie showing that the attorney has not engaged in improper conduct during the suspension period.15
¶ 12 A suspension from the practice of law for a period in excess of two years is tantamount to disbarment in that the suspended lawyer must follow the same procedures for readmittance as would a disbarred counterpart.16 Before an attorney who has been disciplined for more than two years may be readmitted to the practice of law, it must be established that the lawyer’s conduct will conform to the high standards required of a member of the Oklahoma Bar. The burden is on the applicant to demonstrate by clear and convincing evidence that the prerequisites for reinstatement are satisfied.17 The applicant must present stronger proof of qualifications than one seeking first time admission.18
¶ 13 Rule 11.5, Rules Governing Disciplinary Proceedings, 5 O.S.2001, Ch. 1, App. 1-A requires the trial panel to make specific findings regarding whether: 1) the petitioner possesses the good moral character which would entitle him to be admitted to the Bar Association; 2) the petitioner has engaged in the unauthorized practice of law during the period of suspension; and 3) the petitioner possesses the competency and learning in the law required for admission to the practice of law in the State of Oklahoma. In addition, the Court considers the following eight factors: 1) the applicant’s present moral fitness; 2) demonstrated consciousness of the conduct’s wrongfulness and the disrepute it has brought upon the legal profession; 3) the extent of rehabilitation; 4) the original misconduct’s seriousness; 5) conduct after resignation; 6) time elapsed since the resignation; 7) the applicant’s character, maturity, and experience when suspended; and 8) present legal competence.19 Each reinstatement decision is determined on a case-by-ease basis, carefully weighing all factors.20
¶ 14 a. The attorney has not demonstrated the clear and convincing evidence necessary for his readmittance to the practice of law in Oklahoma.
¶ 15 Munson asserts that he provided clear and convincing evidence that his application for reinstatement should be granted. He contends that he substantially complied with Rule 9.1, Rules Governing Disciplinary Proceedings, 5 O.S.2001, Ch. 1, App. 1-A.21 The *102attorney insists that he filed the necessary affidavit, paid the costs of the proceeding, reimbursed the Client Security Fund for the one claim paid on his behalf, the bank for its loses, and that all other parties have been fully reimbursed.22 He argues that he demonstrated his good moral character, competency in the law, and that he has not engaged in the unauthorized practice of law since his 1993 resignation.
¶ 16 The trial panel found that Munson failed to present clear and convincing evidence of his present moral fitness to practice law and consciousness of the wrongfulness of his acts and the disrepute brought on the profession. Nevertheless, the trial panel did believe that Munson met the burden of proof on the issue of his learning and competency in the law. The Bar Association disagrees with Munson’s contention that he substantially complied with Rule 9.1, joining in the trial panel’s recommendation that the attorney has not demonstrated the clear and convincing evidence necessary to support reinstatement and requesting that we deny reinstatement and impose costs of the proceeding. We agree with these recommendations. However, unlike the trial panel, we are not persuaded that Munson met the burden of proof as it relates to his competency to practice law. Our lack of confidence in the attorney’s legal abilities arises from his failure to strictly comply with the rules governing suspension and reinstatement proceedings both in Munson I and in Munson II.
¶ 17 a) Munson’s reliance on his appointment in a prominent criminal case as explaining his actions in misappropriating and converting funds is unconvincing when the attorney did not rely on the criminal proceedings during the hearing leading up to his resignation in Munson II.
¶ 18 In 1986, two years before his initial suspension, Munson was appointed as counsel for Charles Troy Coleman in a well-publicized, high-profile, murder trial which ended in Coleman’s execution. In the reinstatement hearing, the attorney testified that his involvement in the Coleman case put him in a downward “spiral” which led to his first suspension.23 Once he was reinstated, Mun-son testified that he still found himself trying to make up for the “Coleman thing” but that he continued to “spiral” into a position where he felt forced to misuse his client’s funds24 *103going so far as to describe his actions as “robbing Peter to pay Paul.”25
¶ 19 Misappropriation is the most serious infraction occurring with the handling of trust monies.26 There is no question that the attorney misappropriated client funds. What is puzzling is Munson’s after-the-fact reliance on his representation of a criminal defendant to demonstrate how his money problems began and intensified. In Mun-son’s attempt to defend his actions and avoid discipline in Munson II, the cause in which he resigned and from which he now seeks reinstatement, he never once related any of his problems to the defense of Coleman in the hearing before the trial panel. There is not a single reference, in the one-hundred- and-twenty-seven-page transcript of proceedings, where Coleman is even mentioned.27 The lack of any such testimony calls into question Munson’s veracity before the trial panel in the reinstatement proceedings.
¶ 20 b) The record supports a conclusion that Munson engaged in the unauthorized practice of law during his suspension in Munson I and that he was less than truthful about the representation in his testimony before the trial panel on reinstatement.
¶21 The period of suspension in Munson I began on December 12, 1988 and ran through January 4, 1990. As previously noted, it appears that the attorney accepted a probate cause during this time period.28 In its investigation of the current cause, the Bar Association discovered that the attorney filed an application for attorney fees in the United States District Court for the Eastern District on November 10, 1992.29 Attached to that filing was a detailed hourly billing chart for a cause Munson handled for Bill Thompson. The time sheets contain thirty-two (32) entries beginning on the day after the suspension order entered and ending on October 6, 1989.30 These entries, in and of themselves, demonstrate that the attorney was involved *104in the unauthorized practice of law during his initial suspension.
¶ 22 Munson acknowledged that there was a billing record for December 13, 1988 and a number of similar billings in the Thompson case thereafter. Nevertheless, when the attorney was questioned about these billings, he attempted to explain them away as computer programming errors or mistakes of an unnamed assistant.31
¶ 23 The evidence of the unauthorized practice of law while under suspension is damning in and of itself. Similar causes have resulted in discipline ranging from public censure to disbarment depending on the mitigating circumstances.32 Even more trou*105bling is Munson’s unwillingness to be straightforward and honest in his answers regarding the incident.33 Finally, apparently the attorney filed a false affidavit upon his reinstatement in 1990. At the time of his reinstatement without order of the Court, Rule 11.8, Rules Governing Disciplinary Proceedings, 5 O.S. Supp.1989, Ch. 1, App. 1-A,34 required Munson to file a statement averring that he had not engaged in the unauthorized practice of law during his one-year term of suspension. The evidence before this Court demonstrates the falsity of any such statement filed.
¶ 24 c) The attorney’s failure to strictly comply with the conditions of his suspension and the with the provisions of Rule 9.1 militate against a finding of knowledge of the law and competency in its practice.
¶ 25 When the order of suspension in State ex rel. Oklahoma Bar Ass’n v. Munson (Munson II), 1993 OK 12, 848 P.2d 555 issued, the attorney was directed to pay costs of $2,228.51 “within a reasonable time from the date” of the order.35 Munson was notified by the Bar Association in June of 2007 that the costs of $2,228.51 for the 1993 proceeding remained outstanding.36 They were not received by the Bar Association until December 11, 2007.37
¶ 26 Munson testified that he felt that, under the circumstances, his failure to pay the costs of the proceeding for some fourteen *106(14) years was reasonable. Nevertheless, he recognized that others might not agree with his position. We find ourselves among those who disagree. A reasonable time might have been the span of five (5) years, the mandatory suspension period. During that time, Munson could have met the obligation by setting aside $450.00 per year, a not overly burdensome sum.
¶27 Rule 9.1, Rules Governing Disciplinary Proceedings, 5 O.S.2001, Ch. 1, App. 1-A38 provides that when a lawyer is suspended there is an affirmative duty within twenty (20) days, to notify all clients via certified mail with pending business of the inability to represent them. There is also a requirement to formally withdraw from all pending cases. Finally, during the same twenty (20) day period, the lawyer must file an affidavit with the Commission and with the Clerk of the Supreme Court affirming his compliance with the rule and providing a list of the clients notified along with a summary of all other state and federal courts and administrative agencies before which the lawyer is admitted to practice law. The rule provides in mandatory language that “[p)roof of substantial compliance by the lawyer with this Rule 9.1 shall be a condition precedent to any petition for reinstatement.”
¶ 28 Following his suspension in Munson I, the attorney did not strictly comply with the requirements of Rule 9.1. Rather than filing the required affidavit within the twenty (20) day period, he filed it nine (9) days late and found it necessary to supplement it with a list of clients and the agencies and courts before which he practiced ten (10) days later.39 Nevertheless, the paperwork was filed within a reasonable time after suspension and contained all documentation necessary for meeting the standards imposed by the rule. The combined filings represent an instance of substantial compliance.
¶ 29 As early as the date the request for resignation in Munson II was filed, the attorney acknowledged the pending disciplinary proceedings and stated in pertinent part:
“... I have familiarized myself with the provisions of Rule 9.1, RGDP, and do hereby agree to comply with all provisions of Rule 9.1, within twenty (20) days following the effective date of the Order entered by the Supreme Court approving this resignation ....”40
The attorney did not live up to his representation. He did not follow the twenty (20) day mandate of Rule 9.1. No filing was made until March 4, 2008. Some fourteen (14) years after his suspension in Munson II, the attorney filed an affidavit providing that to the “best of his knowledge” he had substantially complied with Rule 9.141 as it related to the notification of clients and the filing of withdrawals in all pending cases. He excuses his inability to provide the affidavits required by the rule “because of the length of time since the Resignation and the present unavailability of the records thereof.”
¶ 30 If Munson had followed the mandate of Rule 9.1 and filed his affidavits within the twenty (20) day mandated period, there would have been no reason to use the passage of time and the destruction or unavailability of records as an excuse for noneompliance. As a partial showing of substantial compliance, Munson relied upon the public nature of his transgressions, i.e. their publication in the local press. However, during the hearing before the trial panel in Munson II, the attorney argued that the complaint should be dismissed. Munson’s reasoning for the assertion was that: 1) the misappropriation of funds did not occur within the lawyer-client relationship;42 and 2) the way *107the matter was handled had kept it from the public.43
¶ 31 Rather than paying costs associated with Munson II, within a reasonable time of the date of the order of suspension, the attorney waited fourteen (14) years and only paid the same upon his decision to file a petition for reinstatement. The attorney substantially complied with Rule 9.1 after his suspension in Munson I. Nevertheless, despite his statement indicating he would familiarize himself with the rule and comply, he failed to do so after his resignation in Mun-son II. His conflicting excuses and reliance on the passage of time are unconvincing and do not provide support for the argument of substantial compliance.
CONCLUSION
¶32 The record presents incontrovertible evidence that Munson engaged in the unauthorized practice of law during his initial suspension. We are faced with evidence that the attorney did not strictly comply with the rules governing either his suspension or his reinstatement. The attorney gave equivoca-ble answers both to questions regarding issues related to his unauthorized practice of law and the facts leading up to his second downfall. Nevertheless, it is obvious that the attorney has done a good deal to get his finances and his life in order.
¶33 In making a reinstatement decision, this Court must disregard feelings of sympathy,44 recognizing that the petitioner’s burden of proof is a heavy one.45 While we are concerned with any adverse effect reinstatement might have on the practicing bar, our foremost consideration is always to protect the public welfare.46 After having given due consideration to the evidence contained in this record and the appropriate factors examined in reinstatement proceedings, we determine that the petitioner has failed to carry his burden to show by clear and convincing evidence47 that he is entitled to reinstatement. Therefore, reinstatement is denied and costs of $1,705.4748 are imposed.
PETITION FOR REINSTATEMENT DENIED; PETITIONER ORDERED TO PAY COSTS OF $1,705.47.
EDMONDSON, C.J., TAYLOR, V.C.J., HARGRAVE, OPALA, WATT, WINCHESTER, COLBERT, REIF, JJ., concur.
KAUGER, J., not participating.