OPALA, Justice.
In this disciplinary proceeding against a lawyer, the issues to be decided are: (1) Is the record, consisting of the stipulated facts and a transcript of proceedings, sufficient for a meaningful de novo consideration of the complaint’s disposition? and (2) Is a four-month suspension an appropriate disciplinary sanction to be imposed for respondent’s professional misconduct? We answer both questions in the affirmative.
The Oklahoma Bar Association [Bar] charged Robert L. Johnston [Johnston or respondent], a licensed lawyer, with one count of professional misconduct. The Bar and Johnston then entered into a stipulation of facts and agreed conclusions of law with a joint recommendation for a four-month suspension to be imposed as professional discipline for that misconduct. A panel of the Professional Responsibility Tribunal [PRT] adopted the parties’ offer for an agreed disposition.
STIPULATION OF FACTS
In November 1990, respondent entered into a contract with Mr. and Mrs. T ... [adoptive parents], Texas residents, to represent them in an adoption proceeding. Their agreement is contained in a letter from respondent to the couple.1 They gave [1140]*1140respondent $10,000, out of which he was to pay (a) all medical bills relating to the pregnancy and (b) his legal fees for handling the adoption.
The biological parents, residents of Oklahoma County, had agreed to place their then-unborn child for adoption with the Ts, who were to pay the medical bills. The baby was born on January 22, 1991 in Oklahoma City. The following day, respondent’s secretary carried the child from the hospital and delivered it to the Ts at the Will Rogers World Airport in Oklahoma City.
On November 23, 1990, respondent deposited the adoptive parents’ $10,000 check in his trust account. Of that amount, he paid $2,120.00 to the attending physician [physician] for the mother's medical care. Respondent stipulated that he “paid himself the balance [of the funds on hand] as attorney’s fees.” 2 The physician was originally scheduled to deliver the child at his clinic, but due to unforeseen complications, the child was born at home. The mother and child were then transferred by AM-CARE to South Community Hospital. This unexpected medical treatment substantially increased the medical care costs to $6,055.58.
On October 24, 1991, the Ts’ Texas counsel filed a grievance with the Bar against respondent because he had failed to take the necessary steps to finalize the adoption proceedings. In fact, he had never filed a petition for adoption on behalf of the Ts. The Bar brought its complaint on February 25, 1992. On March 18, 1992, the same day that respondent filed an answer to the Bar complaint, he paid the medical care providers. Two other bills were paid on June 11, 1992. On the date of the hearing, July 9, 1992, the Bar’s counsel reported that respondent had given him a check ($3,944.42) for the balance of the funds not used for the medical care or related incidental expenses. He did not retain any of the funds for his attorney’s fee.
Respondent failed diligently or competently to work on this matter or to communicate appropriately with his clients. On June 12, 1991, he wrote the biological parents that he was attempting to work out an appropriate settlement with each care giver and that he had notified each one he was assuming responsibility for the debt.3 Despite his representations, respondent failed timely to settle or pay the debts related to the baby’s birth. According to the stipulation, the funds allocated to pay medical care did not remain in respondent’s trust account during the period between the time he received them and the time they were paid.
The State of Oklahoma, where the biological parents reside and the baby was born, and the State of Texas, where the adoptive parents reside, are both parties to the Interstate Compact on the. Placement of Children.4 Respondent was required by the laws and administrative regulations of both states to comply with certain conditions relating to the adoption before he sent the child to Texas. He failed to meet these requirements, such as obtaining the approval of the interstate compact administrator in Oklahoma before allowing the baby to be taken out of state.
On January 23, 1991, when respondent appeared with the biological parents to take their consent to the adoption of the child, he told the court that the adoptive parents were in the process of moving to Oklahoma and would be domiciled in Oklahoma County. Though this statement was admittedly false, the signed consent form approved by the judge indicates that both the biological parents and the judge were [1141]*1141aware of the child’s impending removal from Oklahoma.5
AGREED CONCLUSIONS OF LAW
The parties’ stipulation concedes that Johnston’s misconduct violates the mandatory provisions of Rules 1.1,6 1.3,7 1.4,8 1.15,9 and 8.4,10 Oklahoma Rules of Professional Conduct, and Rule 1.4,11 Rules Governing Disciplinary Proceedings, and constitutes grounds for professional discipline.
CONCESSION AS TO AVAILABLE MITIGATION
The parties submit that (a) respondent paid all bills in the total amount of $6,055.58, (b) respondent has returned all of the residual funds in the amount of $3,944.12 (at the beginning of the hearing he gave the Bar counsel a check in that amount), (c) they expect the adoption will be completed by new counsel, and (d) respondent has not previously been disciplined.
THE PARTIES’ RECOMMENDATION FOR DISCIPLINE
The parties recommend that respondent (a) be suspended from the practice of law for a four-month period and (b) pay the costs incurred in this proceeding.
[1142]*1142I
THE RECORD BEFORE THE COURT IS COMPLETE FOR A DE NOVO CONSIDERATION OF ALL FACTS RELEVANT TO THIS PROCEEDING
The Oklahoma Supreme Court has exclusive original jurisdiction over Bar disciplinary proceedings.12 The court’s review is conducted by de novo consideration of the prosecution that is brought before us.13 Neither the trial authority’s findings nor its assessments with respect to the weight or credibility of the evidence can bind this court.14 In a de novo consideration, in which the court exercises its constitutionally invested, nondelegable power to regulate both the practice of law and the legal practitioners,15 a full-scale exploration of all relevant facts is mandatory.16
The court’s task cannot be discharged unless the PRT panel submits a complete record of proceedings for a de novo examination of all material issues.17 Our responsibility is to ensure that the record is sufficient for a thorough inquiry into essential facts and for crafting the appropriate discipline18 that would avoid the vice of visiting disparate treatment oh the respondent-lawyer.19
Johnston has admitted, and the record sufficiently supports, the allegations of professional misconduct in Count 1.
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OPALA, Justice.
In this disciplinary proceeding against a lawyer, the issues to be decided are: (1) Is the record, consisting of the stipulated facts and a transcript of proceedings, sufficient for a meaningful de novo consideration of the complaint’s disposition? and (2) Is a four-month suspension an appropriate disciplinary sanction to be imposed for respondent’s professional misconduct? We answer both questions in the affirmative.
The Oklahoma Bar Association [Bar] charged Robert L. Johnston [Johnston or respondent], a licensed lawyer, with one count of professional misconduct. The Bar and Johnston then entered into a stipulation of facts and agreed conclusions of law with a joint recommendation for a four-month suspension to be imposed as professional discipline for that misconduct. A panel of the Professional Responsibility Tribunal [PRT] adopted the parties’ offer for an agreed disposition.
STIPULATION OF FACTS
In November 1990, respondent entered into a contract with Mr. and Mrs. T ... [adoptive parents], Texas residents, to represent them in an adoption proceeding. Their agreement is contained in a letter from respondent to the couple.1 They gave [1140]*1140respondent $10,000, out of which he was to pay (a) all medical bills relating to the pregnancy and (b) his legal fees for handling the adoption.
The biological parents, residents of Oklahoma County, had agreed to place their then-unborn child for adoption with the Ts, who were to pay the medical bills. The baby was born on January 22, 1991 in Oklahoma City. The following day, respondent’s secretary carried the child from the hospital and delivered it to the Ts at the Will Rogers World Airport in Oklahoma City.
On November 23, 1990, respondent deposited the adoptive parents’ $10,000 check in his trust account. Of that amount, he paid $2,120.00 to the attending physician [physician] for the mother's medical care. Respondent stipulated that he “paid himself the balance [of the funds on hand] as attorney’s fees.” 2 The physician was originally scheduled to deliver the child at his clinic, but due to unforeseen complications, the child was born at home. The mother and child were then transferred by AM-CARE to South Community Hospital. This unexpected medical treatment substantially increased the medical care costs to $6,055.58.
On October 24, 1991, the Ts’ Texas counsel filed a grievance with the Bar against respondent because he had failed to take the necessary steps to finalize the adoption proceedings. In fact, he had never filed a petition for adoption on behalf of the Ts. The Bar brought its complaint on February 25, 1992. On March 18, 1992, the same day that respondent filed an answer to the Bar complaint, he paid the medical care providers. Two other bills were paid on June 11, 1992. On the date of the hearing, July 9, 1992, the Bar’s counsel reported that respondent had given him a check ($3,944.42) for the balance of the funds not used for the medical care or related incidental expenses. He did not retain any of the funds for his attorney’s fee.
Respondent failed diligently or competently to work on this matter or to communicate appropriately with his clients. On June 12, 1991, he wrote the biological parents that he was attempting to work out an appropriate settlement with each care giver and that he had notified each one he was assuming responsibility for the debt.3 Despite his representations, respondent failed timely to settle or pay the debts related to the baby’s birth. According to the stipulation, the funds allocated to pay medical care did not remain in respondent’s trust account during the period between the time he received them and the time they were paid.
The State of Oklahoma, where the biological parents reside and the baby was born, and the State of Texas, where the adoptive parents reside, are both parties to the Interstate Compact on the. Placement of Children.4 Respondent was required by the laws and administrative regulations of both states to comply with certain conditions relating to the adoption before he sent the child to Texas. He failed to meet these requirements, such as obtaining the approval of the interstate compact administrator in Oklahoma before allowing the baby to be taken out of state.
On January 23, 1991, when respondent appeared with the biological parents to take their consent to the adoption of the child, he told the court that the adoptive parents were in the process of moving to Oklahoma and would be domiciled in Oklahoma County. Though this statement was admittedly false, the signed consent form approved by the judge indicates that both the biological parents and the judge were [1141]*1141aware of the child’s impending removal from Oklahoma.5
AGREED CONCLUSIONS OF LAW
The parties’ stipulation concedes that Johnston’s misconduct violates the mandatory provisions of Rules 1.1,6 1.3,7 1.4,8 1.15,9 and 8.4,10 Oklahoma Rules of Professional Conduct, and Rule 1.4,11 Rules Governing Disciplinary Proceedings, and constitutes grounds for professional discipline.
CONCESSION AS TO AVAILABLE MITIGATION
The parties submit that (a) respondent paid all bills in the total amount of $6,055.58, (b) respondent has returned all of the residual funds in the amount of $3,944.12 (at the beginning of the hearing he gave the Bar counsel a check in that amount), (c) they expect the adoption will be completed by new counsel, and (d) respondent has not previously been disciplined.
THE PARTIES’ RECOMMENDATION FOR DISCIPLINE
The parties recommend that respondent (a) be suspended from the practice of law for a four-month period and (b) pay the costs incurred in this proceeding.
[1142]*1142I
THE RECORD BEFORE THE COURT IS COMPLETE FOR A DE NOVO CONSIDERATION OF ALL FACTS RELEVANT TO THIS PROCEEDING
The Oklahoma Supreme Court has exclusive original jurisdiction over Bar disciplinary proceedings.12 The court’s review is conducted by de novo consideration of the prosecution that is brought before us.13 Neither the trial authority’s findings nor its assessments with respect to the weight or credibility of the evidence can bind this court.14 In a de novo consideration, in which the court exercises its constitutionally invested, nondelegable power to regulate both the practice of law and the legal practitioners,15 a full-scale exploration of all relevant facts is mandatory.16
The court’s task cannot be discharged unless the PRT panel submits a complete record of proceedings for a de novo examination of all material issues.17 Our responsibility is to ensure that the record is sufficient for a thorough inquiry into essential facts and for crafting the appropriate discipline18 that would avoid the vice of visiting disparate treatment oh the respondent-lawyer.19
Johnston has admitted, and the record sufficiently supports, the allegations of professional misconduct in Count 1. We hold the record is adequate for our de novo consideration of respondent’s offending past conduct.
[1143]*1143II
RESPONDENT’S FALSE STATEMENT TO THE TRIAL JUDGE
A.
Rule 8.4(c) — Misrepresentation
The OBA charged Johnston with making a misrepresentation to the trial judge in violation of Rule 8.4(c). That rule, which generally targets fraudulent conduct,20 is directed to a lawyer’s “dishonesty, fraud, deceit or misrepresentation.”21 A misrepresentation must be shown by clear and convincing evidence that the de-clarant had an underlying motive (i.e., bad or evil intent) for making the statement.22 The record is devoid of any indication that Johnston had an improper motive.
Johnston admits that (a) he told the trial judge the adoptive parents were planning to move to Oklahoma from their residence in Texas and (b) the statement is not true. The PRT found the statement would have served no purpose in the judge’s evaluation of the case. Nothing in the record indicates to us that it would have been advantageous for Johnston to misinform the court.23 Without establishing an improper motive for Johnston’s statement, the Bar has not met its burden of proving that a “misrepresentation” was made.
B.
Rule 3.3 — False Statement To A Tribunal
While no “bad or evil intent” is shown by the record, Johnston is not relieved of professional responsibility for his false statement to the court. Any charge of “misrepresentation” to a judge or tribunal also carries with it an included or implied count of making a “false statement” in violation of Rule 3.3(a)(1).24 The converse is not true.
A “false statement” to a tribunal, as distinguished from a “misrepresentation,” requires no proof of “bad or evil intent,”25 nor must it be material.26 It matters not that the Bar failed to plead a specific Rule 3.3 violation. The Bar need only plead sufficient facts that will put the accused attorney on notice of the charges and give him an opportunity to respond to the facts alleged.27
[1144]*1144On de novo consideration of the record, we conclude that the alleged facts sufficiently put Johnston on notice and that he had a fair opportunity to respond to them. He does not deny making the false statement to the court and having actual knowledge28 that his clients did not intend to move to Oklahoma. Even though Johnston claims he might have mistakenly confused the Ts’ case with another one, this does not exonerate him of making a false statement. The fact that the judge in this instance did not seem to rely on the statement is also irrelevant. Under Rule 3.3(a)(1), any incorrect statement of law or fact made to a tribunal by a lawyer having actual knowledge of its falsity, no matter how insignificant, is grounds for discipline. The word “material” was intentionally omitted from Rule 3.3.29 Johnston’s false statement, albeit on a non-material point, is a violation that warrants disciplinary sanction.
III
MISHANDLING FUNDS
The Bar has charged Johnston with improperly managing the funds entrusted to him in violation of Rules 1.1530 and 1.4.31 We employ three different culpability standards when evaluating mishandling of funds: (1) commingling;32 (2) simple conversion;33 and (3) misappropriation, i.e., “theft by conversion or otherwise.” 34 The degree of culpability ascends from the first to the last. Each must be proved by clear and convincing evidence.35
Commingling occurs when the client’s funds are combined with the attorney’s personal funds. Complete separation of a client’s money from that of the attorney’s is the only way in which proper accounting can be maintained.36 When an attorney receives money, part of which is to be paid to a third person and part of which is for the attorney’s fee, all the [1145]*1145funds not clearly identifiable as the attorney’s must be kept separate.37
Johnston admits that he withdrew from his trust account funds that were earmarked for payment of medical bills and placed them in his personal account. By failing to keep his money separate from that due the care givers, Johnston has commingled funds.
The second level of culpability is simple conversion. Rule 1.4(b) establishes that simple conversion occurs when an attorney applies a client’s money to a purpose other than that for which it was entrusted to him.38 By taking out money that was in his trust account and paying himself rather than satisfying all the care givers, Johnston is guilty of simple conversion.39
The third level of culpability is misappropriation, i.e. “theft by conversion or otherwise." This occurs when an attorney has purposely deprived a client of money by way of deceit and fraudé.40 A lawyer found guilty of intentionally inflicting grave economic harm in mishandling clients’ funds is deemed to have committed this most grievous degree of offense.41 A finding that the attorney did so intentionally, regardless of exceptional mitigating factors,42 mandates the imposition of harsh discipline — disbarment.43
The parties agree that Johnston did not intend to misappropriate his clients’ money. The PRT also agreed and concluded that Johnston’s misconduct grew out of his ignorance of proper procedures for holding and distributing the money entrusted to him. On de novo consideration, we agree with the PRT’s conclusion and hold that discipline is warranted for respondent’s mishandling of his clients’ funds.
IV
OTHER MISCONDUCT
Johnston has been charged with other offenses, namely: (1) failing to give competent representation in violation of Rule 1.1;44 (2) failing to act promptly on a matter for which he was hired in violation of Rule 1.3;45 and (3) failing to communicate with his clients in violation of Rule 1.4.46
Professional competence — acting promptly on a matter and communication with a client — is a mandatory obligation imposed upon attorneys. Albeit high, this obligation is the minimum we expect from a lawyer. It epitomizes professionalism. Anything less is a breach of a lawyer’s duty to serve his client.47 Johnston’s failure to maintain these standards — through procrastination and neglectful behavior— warrants imposition of disciplinary sanction.
V
A FOUR-MONTH SUSPENSION IS AN APPROPRIATE SANCTION FOR RESPONDENT’S PAST PROFESSIONAL MISCONDUCT
The court’s responsibility in a disciplinary proceeding is not to punish but to inquire into and gauge a lawyer’s continued fitness, with a view to safeguarding the interests of the public, of the courts [1146]*1146and of the legal profession.48 Imposition of discipline is designed to maintain these goals rather than to be a punitive measure for a lawyer’s misconduct.49
The PRT adopted the parties’ stipulation, recommending that Johnston be suspended from the practice of law for four months and pay all costs incurred in this proceeding.50 Johnston’s professional misconduct stems from one incident. He has now returned all of the residual funds he was holding and has paid in full all of the care givers. None of the clients’ funds went to pay his attorney’s fee.
We recently imposed a three-month suspension sanction for a single act of commingling and conversion of client’s funds.51 Johnston is charged with not only commingling and conversion of funds, but also with making a false statement to the court, professional incompetence, failure to act promptly while representing his clients, and failure to communicate with the clients. While Johnston’s post-complaint return of the clients’ funds operates to bring no detriment to his clients, his actions nonetheless call for discipline. The PRT’s recommendation that Johnston be suspended from the practice of law for a four-month period is approved. Within four months of the date of this opinion, Johnston shall pay costs incurred in this proceeding — $284.77.
Respondent stands suspended from the practice of law for four months from the day this opinion becomes final; costs shall be paid in full before his reinstatement.
HODGES, C.J., LAVENDER, V.C.J., and SIMMS, HARGRAVE, ALMA WILSON and SUMMERS, JJ., concur.
KAUGER and WATT, JJ., concur in part and dissent in part.