Paul Reynolds was fined £290,344 and banned from performing any function in relation to regulated activities on the basis he lacks integrity and as such is not “fit and proper”, the UK financial watchdog said on 20 May.
It found that, between 2005 and 2010, while an ‘approved person’ at Aspire Personal Finance, Reynolds recommended a number of complex and high risk products to often low income and inexperienced clients.
Since July 2014, Reynolds has been working as a senior associate with Holborn Assets in Dubai – which describes itself as an “internationally-owned global financial advisory group” – as well as an international financial adviser with Holborn Assets LLC, according to Reynolds’ Linkedin profile.
His profile stated Reynolds previous position as “25 years experience in helping clients become financially well organised”.
Holborn’s website describes Reynolds as a “leader in his field” and as an adviser who takes a “genuine interest in his clients”.
The FCA said Reynolds withdrew a challenge to its findings via the Upper Tribunal last month, but it has been reported he would have continued to argue his innocence but for the sizeable fees required to mount a defence.
When recommending unsuitable investment to UK clients while at Aspire, the FCA said Reynolds was aware he could not justify the suitability of the products he was selling.
In some cases, Reynolds’ clients were unaware that they had invested in unregulated investments and were not told of the associated risks.
Suitability letters found on the clients’ files, which did explain the risks, had not been sent to the clients, the FCA said.
During its investigation, the FCA found Reynolds had engaged in a string of unsuitable practices.
He recklessly recommended high risk investment products to eight retail clients, when he was aware that he could not justify their suitability.
Also he was involved in retrospectively creating documents which explained the risks of the products for client files and represented that they were contemporaneous and had been sent to his clients.
The FCA found he retrospectively created signatures purporting to be the signatures of two clients on sophisticated investor certificates to suggest that UCIS products could legitimately be promoted to them.
Reynolds was also found to be involved in producing inflated valuations to conceal the poor performance of the investments that he had recommended.
He made investments on behalf of two clients without their knowledge or authorisation, and was involved in submitting loan facility and investment applications, on behalf of a number of his clients, which contained inflated incomes and other false and misleading information.
Georgina Philippou, acting director of enforcement and market oversight at the FCA said: “People should be able to trust advisers to recommend products which will suit their needs. Today’s fine reflects the fact that we will not hesitate to take action against firms or individuals who fail to put the best interests of their clients first.”