{"id":611049,"date":"2026-04-19T21:16:46","date_gmt":"2026-04-19T19:16:46","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/toni-fox-bryant-anor-v-the-financial-conduct-authority-2\/"},"modified":"2026-04-19T21:16:46","modified_gmt":"2026-04-19T19:16:46","slug":"toni-fox-bryant-anor-v-the-financial-conduct-authority-2","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/toni-fox-bryant-anor-v-the-financial-conduct-authority-2\/","title":{"rendered":"Toni Fox-Bryant & Anor v The Financial Conduct Authority"},"content":{"rendered":"
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1. This is an interlocutory decision about an Unless Order. In Breen v HMRC [2023] UKUT 252 (TCC), the Upper Tribunal recommended that reasoned decisions about Unless Orders be published, so that \u201cother judges and the public can understand the decision-making process involved\u201d. Those comments related to the Tax Chamber of the First-tier Tribunal, but there is no reason why they should not apply equally to the Upper Tribunal. I have therefore directed that this interlocutory decision be published. Introduction 2. Ms Fox-Bryant and Mr Price (\u201cthe Applicants\u201d) were the owners and directors of CFP Management Ltd (\u201cCFP\u201d), a small financial services advisory firm. CFP had entered into arrangements with another company to provide advice relating to the transfer of pensions from defined benefit schemes to defined contribution schemes. 3. The Financial Conduct Authority (\u201cthe Authority\u201d) carried out a review of a sample of 21 of CFP\u2019s client files for the period from 21 April 2015 and 31 October 2017 (\u201cthe File Review\u201d). CFP subsequently entered liquidation. 4. On 3 May 2023, the Authority issued Decision Notices to both Applicants under the Financial Services and Markets Act 2000 (\u201cFSMA\u201d). By the Decision Notices, the Authority withdrew the Applicants\u2019 approvals to perform senior management functions and imposed financial penalties; Ms Fox-Bryant\u2019s Decision Notice also included a prohibition order under s 56 of FSMA. The Applicants referred the Decision Notices to the Tribunal (\u201cthe References\u201d). 5. On 11 October 2023, the Authority applied for directions in relation to the Reference (\u201cthe Application for Directions\u201d). This was supported by a bundle of 247 pages (\u201cthe Bundle\u201d), which included: (1) the Decision Notices; (2) the Authority\u2019s Statement of Case, including at Annex 1 a summary of the File Reviews (\u201cAnnex 1\u201d). Ms Fox-Bryant is named as the Adviser in 12 of the 21 cases reviewed; (3) the Applicants\u2019 Reply to the Statement of Case (\u201cthe Reply\u201d); and (4) relevant correspondence between the parties. 6. Of the draft directions, only the first was in dispute. This was an \u201cUnless\u201d Order, which read: \u201cUnless the Applicants by 4pm on 27 October 2023 provide the Authority with proper particulars of their response to Annex 1 to the Authority\u2019s Statement of Case, including all matters therein that the Applicants dispute and the reasons that they dispute such matters, then: (a) paragraphs 33, 34 and 39 of the Applicants\u2019 Reply shall be struck out; and (b) the Applicants will be taken to have admitted paragraphs 66 to 90, 94, 107 to 109, and 123 of the Authority\u2019s Statement of Case.\u201d 7. The Authority asked that the Application for Directions be determined at a hearing. Having considered that Application and the Bundle, I decided that it was in the interests of justice to decide it on the papers. That is because the parties\u2019 positions are clear from the correspondence, and because an oral hearing would require further time and costs, both for the parties and for the Tribunal; it also risks delaying the listing and hearing of the appeals. 8. I first consider and decide the Application for Directions; my Directions to the parties are set out at the end of this judgment. Paragraph 34 9. Paragraph 34 of the Reply reads: \u201cThe Applicants have not had access to the files (they are with the CFP liquidator) and are unable to provide any sensible commentary until the files are disclosed.\u201d 10. The Authority\u2019s position is that it has disclosed the client files relevant to the File Review three times: on 9 November 2022, 20 January 2023 and 15 September 2023. Mr Fatchett\u2019s email to the Authority dated 27 September 2023 explicitly recognises that the Applicants have the client files. Paragraph 34 is therefore incorrect and it is struck out. Paragraph 36 11. Paragraph 36 reads: \u201cFor reasons set out prior, the Applicants have not reviewed the files referred to in the 16th December 2020 letter, nor have they had access to the files since April 2021.\u201d 12. Consistently with my decision in relation to paragraph 34, the final part of the above sentence, reading \u201cnor have they had access to the files since April 2021\u201d is also struck out. Paragraphs 33 and 39 13. The Authority\u2019s case is based in large part on the outcome of the File Reviews, which found that (a) a significant proportion of the advice provided by the Applicants was unsuitable, and (b) the suitability of some advice could not be assessed due to material information gaps. The Applicants explicitly accept in the Reply that \u201cthe cornerstone of the Authority\u2019s case are the file and systems failings (which are materially based on the 16December 2020 file reviews)\u201d. 14. Paragraph 33 of the Reply is a response to paragraphs 66 to 90 of the Statement of Case. Those paragraphs set out, by way of examples, three cases taken from Annex 1. Paragraph 33 reads: \u201cthe Applicants deny the files are unsuitable\u201d. 15. Paragraph 39 then reads: \u201cThe Applicants will ask to review the December 2020 files and to show that they are within the bounds of being acceptable. Where failings are found, they are not sufficiently seriously [sic] to warrant the serious financial penalties being sought.\u201d 16. By the Application for Directions, the Authority asked that the Applicants be required to provide \u201cproper particulars\u201d of the reasons why they deny that the files are unsuitable, and why any failings are \u201cnot sufficiently serious\u201d to warrant the financial penalties. 17. In deciding that issue, I considered the correspondence between the parties and the relevant law. The correspondence is summarised below, followed by my reasons for agreeing with the Authority. The correspondence 18. On 12 September 2023, the Authority asked the Applicants to file and serve an amended Reply, so as to provide their reasons why they deny that files considered in the File Review are unsuitable and\/or contained material information gaps. 19. On 27 September 2023, Mr Fatchett of FS Legal Solicitors replied on behalf of the Applicants; his email said that Applicants were not responding to the Authority\u2019s request because they had: \u201cno resources to do so. This would require expert evidence to counter [the Authority\u2019s] own analysis\u201d. 20. The Authority replied on 5 October 2023, saying: \u201cIt is not clear to us that your clients are unable to afford expert assistance, but in any event, we do not understand why your clients \u2013 who were both pension transfer specialists \u2013 cannot explain why they disagree with the conclusions of the file reviews. Moreover, they both have first-hand knowledge about the contents of the client files. Consequently, they are very well placed to explain why they \u2018deny that the files are unsuitable\u2019. Absent a proper explanation from your clients as to why they disagree with the file review outcomes, neither the Authority nor the Court will be able to manage this case appropriately. The scope of necessary evidence, and the length of trial, will depend upon what matters are actually in dispute.\u201d. 21. On 9 October 2023, FS Legal responded, stating that the Applicants were \u201cnot going to amend the Reply\u201d, and that the \u201cfundamental issue\u201d was that the Authority had earlier informed the Applicants that they did not need to respond to the File Reviews, and that whether the files were unsuitable was \u201cfor the Upper Tribunal to determine\u201d. The Authority then made the Application for Directions. Reasons for allowing the Application in relation to paragraphs 33 and 39 22. I agree with the Authority that the Applicants must either provide proper particulars of the reasons why they deny the Authority\u2019s conclusions based on the File Reviews, or paragraphs 33 and 39 must be struck out. That is for the reasons set out below. Party has to know the case it has to meet 23. It is well-established that the purpose of pleadings is so that the other party knows the case it has to meet: see British Airways Pension Trustees Ltd v Sir Robert McAlpine & Sons Ltd\u00a0(1994) 72 BLR 26, where Saville LJ said at 33-34: \u201cThe basic purpose of pleadings is to enable the opposing party to know what case is being made in sufficient detail to enable that party properly to prepare to answer it.\u201d 24. That passage was affirmed by the House of Lords in Three Rivers District Council v Bank of England [2001] UKHL 16; [2001] 2 All ER 513 per Lord Hope at [49]. Lord Hope also endorsed the following dicta from Lord Woolf MR\u2019s judgment in McPhilemy v Times Newspapers Ltd\u00a0[1999] 3 All ER 775, 792J-793A: he said that pleadings were \u201crequired to mark out the parameters of the case that is being advanced by each party\u201d and \u201cin particular\u201d were \u201ccritical to identify the issues and the extent of the dispute between the parties\u201d. Those authorities have been frequently cited and reaffirmed by subsequent courts and tribunals. 25. The Applicants have provided no reasons as to why they deny that (a) the advice given to clients was unsuitable, or (b) the suitability of some advice could not be assessed due to material information gaps. I agree that unless the Applicants provide further particulars, the Authority cannot know the case it has to meet, and this is a basic requirement of pleadings in the Upper Tribunal, just as it is in the courts. The Upper Tribunal\u2019s role 26. The Applicants\u2019 position is that the question of the suitability or otherwise of the advice given was \u201cfor the Upper Tribunal to determine\u201d. However, before the Upper Tribunal can determine that issue, it requires pleadings which are sufficiently particularised for the position of the parties at the substantive hearing to be understood and evaluated. The Upper Tribunal also has to case manage the Application in advance of that substantive hearing: this includes deciding resource allocation, and the length and timing required by the appeal. The Applicants must therefore provide particularised pleadings in advance of the hearing. The Rules 27. Schedule 3, paragraph 5(2) of the Tribunal Procedure (Upper Tribunal) Rules 2008 sets out the requirements for a reply to a statement of case: This provides (emphasis added): \u201cThe reply must\u2014 (a) state the grounds on which the applicant relies in the reference; (b) identify all matters contained in the respondent's statement of case (which are disputed by the applicant; (c) state the applicant's reasons for disputing them.\u201d 28. The Applicants have therefore failed to comply with Schedule 3, paragraph 5(2)(c) of the Upper Tribunal Rules, because the Reply contains a bare denial of what the Applicants have accepted is the \u201ccornerstone\u201d of the Authority\u2019s case. The burden of proof 29. In a case such as this, the burden of proof rests on the Authority. However, that does not mean that an Applicant can simply deny the case the Authority has advanced. As Judge Berner said in Badaloo v the Financial Conduct Authority [2017] UKUT 158 (TCC) at [50] \u201cthe legal burden of proof in a reference of this nature is\u2026 on the Authority. But \u2026that does not absolve an applicant from putting forward their own case in response to the case made by the Authority. Once such a case has been made, supported by evidence, the evidential burden may shift, and it is therefore essential in those circumstances for a tenable contrary case to be raised by the applicant.\u201d Lack of resources\/expert evidence? 30. The Applicants say that expert evidence would be required to \u201ccounter\u201d the analysis in the File Reviews, and they do not have the resources to instruct an expert. For the reasons already set out in this decision, neither would provide a justification for their failure to particularise their pleadings. There are also the following additional reasons: (1) As the Authority notes, the Applicants were both pension transfer specialists, and can reasonably be expected to be able to give their own views, on the basis of their knowledge, training and experience, as to why they disagree with the conclusions of the File Reviews, without needing to instruct an expert. (2) The Authority also says that both Applicants had \u201cfirst-hand knowledge about the contents of the client files\u201d, and that does not appear to be in dispute: I note that Ms Fox-Bryant was the adviser in 12 of the 21 cases considered by the File Review. (3) The evidence previously provided to the Authority and the Upper Tribunal shows that they have financial resources; these have been considered in the separate Costs Application decision. The email from the Authority 31. As recorded above, one of the reasons given by the Applicants for not providing any particulars of its denials was that the Authority had earlier informed CFP that it did not need to respond to the File Reviews; Mr Fatchett said this was the \u201cfundamental issue\u201d in the appeal. 32. The background to his submission is that on 16 December 2020, the Authority provided CFP with a letter summarising the result of the File Review. On 17 December 2020, Mr Fatchett informed the Authority that the Applicants were \u201clooking to appoint an insolvency practitioner\u201d in relation to CFP. Mr Derek Murdoch of the Authority responded the same day, saying: \u201cIn terms of responding to our specific feedback and file review findings, in circumstances where the firm does not have the funds to consider and as appropriate respond to our feedback and request for review work, we would not expect the firm to do so. However, the impact of a lack of response from the firm would need to be considered by my Enforcement colleague along with any alternative means for them to gather the information they may require. For example, it may be possible for information to be requested directly from individuals.\u201d 33. The Applicants can of course refer to and rely on the email from Mr Murdoch to explain why CFP did not respond to the results of the File Review, and Ms Elek accepted in the Application for Directions that the Authority \u201cdoes not seek to restrict the Applicants\u2019 ability to argue that the \u2018fundamental issue\u2019 is the Authority\u2019s own conduct following the File Review\u201d. 34. However, Mr Murdoch\u2019s email does not allow the Applicants to bypass both the obligations imposed by the Rules and the well-established requirement that pleadings set out each party\u2019s case \u201cto enable the opposing party to know what case is being made in sufficient detail to enable that party properly to prepare to answer it\u201d. Paragraphs of the statement of case, 35. The Authority has also applied for the Upper Tribunal to direct that, if proper particulars are not provided, \u201cthe Applicants will be taken to have admitted paragraphs 66 to 90, 94, 107 to 109, and 123 of the Authority\u2019s Statement of Case\u201d. I move on to considering those paragraphs. Paragraphs 66-90 36. As noted above, paragraphs 66 to 90 sets out three examples taken from Annex 1. The Applicants\u2019 Reply to those paragraphs of the Statement of Case consists of paragraph 34, which I have struck out, and paragraph 33, which is the subject of the Unless Order. 37. I therefore agree with the Authority that unless the Applicants comply with the Unless Order, they will be taken to have admitted paragraphs 66-90. Paragraphs 94, 107-109 and 123 38. I next considered whether, if the Applicants do not comply with the Unless Order, it should follow that they have also admitted the points contained within paragraphs 94, 107-109 and 123 of the Statement of Case (\u201cthe remaining paragraphs\u201d). 39. Paragraph 94 is headed \u201cinformation collection failings\u201d and sets out the \u201cmaterial information gaps\u201d which on the Authority\u2019s case based on the File Review, prevented an assessment of suitability. 40. Paragraphs 107-109 summarise and exemplify the Authority\u2019s finding that unsuitable advice was given to clients. Paragraph 123 states that insufficient information was provided to 17 out of the 21 clients who formed part of the File Review, including by way of Suitability Reports. 41. I agree with the Respondent that these paragraphs are directly related to the File Review, and that if the Applicants do not comply with the Unless Order, they should also be taken to have admitted the points contained within each of the remaining paragraphs. 42. Although not referred to in the Application for Directions, the position is the same for paragraph 124 of the Statement of Case. It reads \u201cFurther, Suitability Reports contained the text quoted at paragraph 70 above, and paragraph 71 is repeated\u201d. It thus simply repeats two paragraphs which have already been considered as part of paragraphs 66-90. Timing for compliance 43. The draft directions proposed that the Applicants should have three weeks to comply with the Unless Order. I accept that a highly relevant factor is that the Applicants have had the relevant files since 9 November 2022, so for almost a year. 44. However, Annex 1 runs to 45 closely typed pages of detailed findings. In my judgment, it is reasonable and proportionate to allow the Applicants until 31 December 2023 to comply with the Order. The dates for compliance with the other Directions have been amended in consequence. DIRECTIONS For the reasons set out above, it is directed that: 1. The Reply is to be amended so as to remove paragraph 34, and the phrase \u201cnor have they had access to the files since April 2021\u201d from paragraph 36. 2. Unless the Applicants by 5pm on 31 December 2023 file and serve an amended Reply to the Statement of Case, which contains proper particulars of their response to Annex 1, including all matters therein that they dispute and the reasons that they dispute such matters, then: (a) paragraphs 33 and 39 of the Reply shall be struck out; and (b) the Applicants will be taken to have admitted paragraphs 66 to 90, 94, 107 to 109, and 123-124 of the Statement of Case. 3. In complying with the Unless Order, the Applicants are to provide both a marked up copy of the Reply showing the paragraphs struck out or otherwise amended, and a clean copy with revised numbering. 4. By 5pm on 19 February 2024, the parties shall exchange witness statements and serve the same on the Upper Tribunal at 5pm. 5. By 5pm 19 March 2024, the parties are to provide the Upper Tribunal with dates to avoid for a six day hearing (to include a reading day for the Upper Tribunal), beginning with 1 May 2024 and ending on 31 December 2024. ANNE REDSTON UPPER TRIBUNAL JUDGE RELEASE DATE: 25 October 2023<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

1. This is an interlocutory decision about an Unless Order. In Breen v HMRC [2023] UKUT 252 (TCC), the Upper Tribunal recommended that reasoned decisions about Unless Orders be published, so that \u201cother judges and the public can understand the decision-making process involved\u201d. Those comments related to the Tax Chamber of the First-tier Tribunal, but there is no reason why…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[7884],"kji_chamber":[],"kji_year":[24566],"kji_subject":[7612],"kji_keyword":[8252,7664,7975,10545,7636],"kji_language":[7611],"class_list":["post-611049","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-upper-tribunal-tax-and-chancery-chamber","kji_year-24566","kji_subject-fiscal","kji_keyword-applicants","kji_keyword-authority","kji_keyword-paragraph","kji_keyword-paragraphs","kji_keyword-tribunal","kji_language-anglais"],"yoast_head":"\nToni Fox-Bryant & Anor v The Financial Conduct Authority - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/toni-fox-bryant-anor-v-the-financial-conduct-authority-2\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Toni Fox-Bryant & Anor v The Financial Conduct Authority\" \/>\n<meta property=\"og:description\" content=\"1. This is an interlocutory decision about an Unless Order. In Breen v HMRC [2023] UKUT 252 (TCC), the Upper Tribunal recommended that reasoned decisions about Unless Orders be published, so that \u201cother judges and the public can understand the decision-making process involved\u201d. 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This is an interlocutory decision about an Unless Order. In Breen v HMRC [2023] UKUT 252 (TCC), the Upper Tribunal recommended that reasoned decisions about Unless Orders be published, so that \u201cother judges and the public can understand the decision-making process involved\u201d. 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