PENALTY – Breach of APER 6 – Decision Notice issued in ignorance of
financial circumstances of Applicants – Penalties reduced to take account of
hardship – Fuller details of financial circumstances received by FSA after
Decision Notice – Whether Tribunal should increase penalties – Implication
of Applicants’ non-cooperation with the FSA (APER 4)- Decision Notice
made no determination regarding breaches of APER 4 – Whether penalties
should be imposed for such breaches - No.