Regulations
By Pankaj K
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How the Fines Got Recalculated. The FCA originally wanted bigger penalties. The Tribunal pushed back on that — not on the bans,…
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The Structure That Made It Possible. HDIFA wasn't a standalone firm — it operated as an appointed representative of FSML.
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The UK's Upper Tribunal has backed the Financial Conduct Authority's decision to permanently ban Richard Fenech and Heather Dunne from financial services. Both bans stand.
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The case centers on pension transfer advice given between April 2015 and June 2017. Dunne, operating as Heather Dunne Independent Financial Adviser — known as HDIFA — recommended…
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Fenech's firm, Financial Solutions Midhurst Ltd (FSML), is where Dunne's business was registered as an appointed representative.
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So the bans are total. The fines are reduced but still real.
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It's worth being clear about what the Tribunal didn't change. Both individuals are out of financial services. The backdating finding stuck. The dishonesty findings stuck.
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Related: Goldman Sachs Spots Two European Stocks With 100%-Plus Upside on Its Conviction List
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Appointed representative arrangements are pretty common in UK financial services. A smaller adviser or firm plugs into a larger, FCA-authorized firm's regulatory permissions.
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The FCA has been tightening its approach to appointed representative oversight for a while now.
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Both Dunne and Fenech have 14 days from the Tribunal's decision to file an appeal if they want to challenge the ruling. No word yet on whether either plans to do so.
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The FCA said the case shows why trust and integrity aren't optional in financial services. The regulator has pushed this line consistently in DB pension transfer cases, and it's…
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The FCA's decision notice on Dunne dates to 2024. The Tribunal's review and this ruling came after that.
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Related: Missouri Men Charged in $245 Million Bitcoin Theft Attempt
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Tribunal decisions are published publicly, which means the full reasoning is available for anyone in the industry who wants to understand exactly where Fenech and Dunne crossed…
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