Mr Varley’s actions left Dickinsons without professional indemnity cover and the firm went into voluntary liquidation as a result.

The FCA said he knowingly performing a controlled function without approval and provided investment advice to retail customers when he knew he was not qualified or approved to do so.

The regulator also found that Mr Varley failed to act with integrity as a director (CF1) and compliance oversight (CF10) controlled function (CF) holder and “is therefore not a fit and proper person”.

Mr Varley worked at Dickinsons Financial Management Limited (Dickinsons), a small Warwickshire-based financial advisory firm, where he held a customer adviser function (CF30) until January 2013.

Following the Retail Distribution Review, the regulator introduced rules requiring advisers to hold a minimum level of qualification to be approved for a CF30 function. Although his CF30 approval was removed in January 2013, Mr Varley continued to advise retail customers between January 2013 and September 2017.

The FCA said Mr Varley also repeatedly misled his fellow directors at Dickinsons by providing false information in board meetings about sitting and passing the relevant exams required for him to continue advising, and falsely claimed that he had applied to the FCA for approval as a CF30 but the FCA had not updated the Financial Services Register. No application was ever made.

Mr Varley also provided false information to Dickinsons’ professional indemnity insurance providers about the qualifications he held, in order to be insured to advise retail investors after 2013.

As part of his CF10 function, Mr Varley was responsible for providing regulatory information to the FCA in Dickinsons’ retail mediation activities returns. In these returns Mr Varley misled the regulator into believing that one person at Dickinsons was providing retail investment advice to customers when two people were. He also provided false explanations to the FCA to conceal his misconduct.

The FCA noted in its final notice that Mr Varley’s actions led to Dickinsons going into voluntary liquidation and being dissolved, as well as leaving a potential risk of loss to consumers.