The Upper Tribunal has affirmed the Financial Conduct Authority’s (FCA) decision to impose substantial fines on Toni Fox and David Brian Price, former directors of CFP Management Ltd, for operating a deficient pension transfer advice model. The ruling, announced on 7 June 2025, underscores significant breaches in regulatory standards, resulting in fines of £567,584 for Fox and £465,415 for Price, alongside bans from working in financial services and the revocation of their senior management approvals.
Between April 2015 and October 2017, CFP Management Ltd advised on 1,470 pension transfers valued at over £392 million. The tribunal found that Fox, who designed the advice model, and Price, who oversaw its operation, implemented a system that led to unsuitable pension transfers, including for 33 members of the British Steel Pension Scheme. The model was deemed to pose a serious risk to consumers, with the tribunal concluding that both individuals lacked the integrity required for regulated financial roles.
Therese Chambers, FCA’s executive director of enforcement and market oversight, stated:
“The tribunal’s decision confirms that Fox and Price are unfit for regulated financial roles. Their reckless conduct fell significantly short of the standards expected in our industry, endangering consumers’ financial security.”
The final fines reflect adjustments based on updated financial information and recent guidance on tax and interest calculations. Initially, the FCA had proposed higher penalties of £681,536 for Fox and £632,594 for Price, which were revised to ensure fairness.
Previous FCA Action in 2023
This ruling follows earlier regulatory action in September 2023, when the FCA provisionally fined Fox and Price a combined £1.3 million (£681,536 and £632,594, respectively) for their roles in the flawed pension transfer model. At that time, the FCA highlighted that over 99% of CFP’s advice recommended transfers, with more than 90% failing to comply with regulatory standards. The model, designed by Fox and overseen by both directors, prioritised transfers without adequately considering clients’ financial circumstances, risk tolerance, or capacity for loss.
During the period in question, CFP charged fees ranging from £1,500 to £20,000 per client for transfer recommendations, while levying £500 for advice against transferring. Fox and Price personally benefited, receiving £473,289 and £439,302, respectively, through salaries, dividends, and pension contributions. The FCA described the model as a “machine to churn out recommendations,” putting clients’ retirement savings at risk. Fox and Price contested the 2023 decision, referring it to the Upper Tribunal, which has now upheld the FCA’s findings with adjusted penalties.
Ongoing Implications
Despite their 30 years of combined experience in the pensions industry, Fox and Price’s actions led to significant consumer harm. The tribunal’s ruling reinforces the FCA’s commitment to holding senior managers accountable and protecting consumers from unsuitable financial advice. The bans and fines serve as a stark reminder of the importance of robust, client-focused processes in pension transfer advice.
