The FCA also plans to ban the two who are accused of making large sums through their Birmingham-based financial adviser business over several years.

The duo - who face fines totalling £1.31m - have referred their case to the Upper Tribunal so any fines and the FCA's proposed ban on them are provisional until their cases have been heard.

The FCA said the two were former directors of CFP Management Ltd (CFP) which went into liquidation in April 2021 following asset restrictions being imposed on the firm in 2020.  

The watchdog said that between 21 April 2015 and 31 October 2017, CFP, through its Appointed Representative, gave advice on 1,470 transfers together worth more than £392 million.

The FCA said Ms Fox designed the firm's pension transfer model and signed off on almost all of the advice.

As directors of CFP, Ms Fox and Mr Price had oversight of the operation of the pension transfer model. Over 99% of the advice was to transfer and over 90% of the advice "did not comply" with FCA rules.

Of those advised, 33 clients were members of the British Steel Pension Scheme. 

Despite both having 30 years’ experience in the pensions industry, Ms Fox and Mr Price provided advice without proper consideration of clients’ financial circumstances and objectives, attitude to risk and capacity for loss, the FCA said.

The regulator said the firm’s flawed business model that they designed and operated gave rise to a significant risk that many clients transferred out of their defined benefit pension when it was not suitable for them to do so.  

CFP received a fee of between £1,500 and £20,000 from each client they advised to transfer and charged £500 to clients recommended not to transfer.

Both Ms Fox and Mr Price made substantial gains from this business - Ms Fox received £473,289 in salary, dividends and pension contributions from CFP and Mr Price made £439,302. 

Therese Chambers, joint executive director of enforcement and market oversight at the FCA said: "Ms Fox and Mr Price’s misconduct meant that customers did not receive the advice they needed when trying to secure comfort and peace of mind for their retirement.  

"Despite having a wealth of experience in the industry, they both oversaw and designed a deeply flawed advice model that was little more than a machine to churn out recommendations to transfer, placing people’s hard earned retirement money at risk."