The Upper Tribunal has upheld the Financial Conduct Authority’s decision to ban Toni Fox and David Brian Price from working in financial services, revoke their senior management approvals and impose financial penalties for misconduct in pension transfer advice. The Tribunal endorsed recalculated fines of GBP 567,584 for Fox and GBP 465,415 for Price. Between 21 April 2015 and 31 October 2017, the directors of CFP Management Ltd advised on 1,470 pension transfers worth over GBP 392 million using an advice model they designed and operated that was intended to lead to a transfer. The Tribunal agreed the process created a real risk of customer harm and amounted to a very serious breach of FCA rules, including in relation to members of the British Steel Pension Scheme, and concluded both individuals lack the integrity required to work in the industry. The FCA’s original penalty figures of GBP 681,536 (Fox) and GBP 632,594 (Price) were revised following the Tribunal’s March 2025 guidance on calculating tax and interest on sums to be returned, and the Tribunal has now upheld the FCA’s final calculations.