The FSA gave Sett Valley Insurance Services a Decision Notice on 27 January 2010 which notified Sett Valley that pursuant to section 206 of the Financial Services and Markets Act 2000, and on the basis that Sett Valley has agreed to undertake certain remedial action, the FSA had decided to impose a financial penalty of £28,000 on Sett Valley in respect of breaches of the FSA’s Principles for Businesses, between 1 December 2001 and 1 May 2009 and section 20(1)(a) of the Act by conducting pension transfers outside the scope of its Part IV permission.

This case highlights the risks posed by limited control and oversight and the failure of senior management to ensure that their firm can demonstrate the suitability of its advice.

Both of Sett Valley’s partners, Leslie Lugsden and John Hargreaves, were responsible for the problems identified within the firm, and therefore failed in their roles as approved persons performing a significant influence function to ensure that their firm complied with the FSA’s rules.