Clay and Clark were convicted back in 2014 after they pleaded guilty to fraud and forgery but a last-minute dispute about elements of the case against Clay dragged out the process until late last year.
As partners running UK-based investment vehicle Arck, Clay and Clark had sold and marketed unregulated property investments to retail investors through advisers between 2006 and 2012.
The products were sold through self-invested personal pensions (SIPP) run by HD Administrators, of which the pair were directors.
It is estimated more than £50m was invested in these products by individual investors and, in some cases, IFAs themselves.
On 22 November 2013, Clay and Clark were charged with fraud and forgery by the Serious Fraud Office and Nottinghamshire Police.
On 4 July 2014, Clark pleaded guilty to two counts of forgery and on 3 October 2014, she pleaded guilty to three counts of fraud. On 19 December 2014, Clay pleaded guilty to three counts of fraud.
Last October, Clay was sentenced to 10 years and 10 months’ imprisonment while Clark received a two-year prison sentence, which was suspended for two years.
The FCA concluded on 25 October this year that both Clay and Clark were “not fit and proper to carry on any function in relation to any regulated activities”.
As well as banning the pair, the regulator withdrew Clark’s FCA approval in relation to HD Administrators. Clay has not been FCA approved since 2005.