FCA Files High Court Claim Against Loan-Note Seller Hunter Jones

The Financial Conduct Authority has begun High Court proceedings against Osborne Baldwin Limited, which trades as Hunter Jones and Hunter Jones Group, alleging that the loan-note seller carries out regulated activity without authorisation. The regulator announced the action on 21 September 2026.

The FCA is asking the court to stop Hunter Jones carrying out regulated activity and to require money to be returned to investors. It said the proceedings are at an early stage, that the court has not yet determined the claim, and that no trial date has been set.

Consumers who deal with unauthorised firms “are at greater risk and may lose access to important protections if things go wrong,” the FCA said, and it encouraged consumers to use its Firm Checker tool. Anyone who has invested through Hunter Jones and is concerned about what the proceedings mean for them, or who has information to share with the regulator, should contact [email protected]. The FCA said it will provide more information for investors when it is able to do so.

The Company and Its Former Principal

Osborne Baldwin Limited, company number 08744562, is an active private limited company incorporated on 23 October 2013, according to its Companies House profile. It was registered under the name Haspel Limited until 31 October 2014. Its registered office is at One Oaks Court, Warwick Road, Borehamwood, Hertfordshire, WD6 1GS, and its registered nature of business is financial intermediation not elsewhere classified. Its last accounts were made up to 31 December 2024, and its next accounts, covering the period to 31 December 2025, are due by 30 September 2026.

Hunter Jones previously operated as an appointed representative of Equity for Growth (Securities) Limited, a corporate finance firm that acted as principal for a number of appointed representatives between 2015 and 2020, also including Amyma Ltd. An appointed representative carries on regulated activity under the responsibility of an authorised firm, known as the principal.

According to an FCA account of the EFG liquidation published in March 2026, EFG received a large number of complaints from investors that were referred to the Financial Ombudsman Service, including claims relating to mini bonds issued by unauthorised companies and promoted by its appointed representatives Amyma and Hunter Jones. The FCA considered EFG insolvent and without appropriate resources in relation to those ombudsman claims, meaning it could not pay any compensation consumers may have been owed. The regulator filed a petition on 18 October 2024 for EFG to be wound up so that claims could be assessed by the Financial Services Compensation Scheme, and on the same date it placed restrictions on the firm preventing it from conducting regulated activities. On 25 March 2026, the High Court ordered that EFG be wound up. The Official Receiver, part of the Insolvency Service, is carrying out the liquidation, and the FSCS is open to customer claims while it investigates whether they meet the qualifying conditions for compensation.

Ombudsman Findings on Dolphin Loan-Note Sales

A final Financial Ombudsman Service decision, reference DRN-4807617, records how Hunter Jones arranged Dolphin loan-note investments while operating under EFG. Hunter Jones became an appointed representative of EFG on 4 May 2018, under an agreement limited to arranging deals in investments, for which EFG accepted responsibility.

The decision concerned a complainant identified as Ms R, who was 90 years old at the time. She invested £20,000 in Dolphin loan notes on 22 January 2019 and a further £10,391.78 on 19 February 2019, the latter a reinvestment of a £10,000 investment made on 13 March 2017 together with returns she had received on it. The Dolphin loan notes now have no value.

Ombudsman Laura Parker found that Hunter Jones carried on the regulated activity of arranging deals in investments under Article 25(1) and/or Article 25(2) of the Regulated Activities Order, citing its handling of expression-of-interest and loan-note-offer paperwork that it sent to Ms R and forwarded to Dolphin. EFG had argued that Hunter Jones acted only as an introducing agent for certified exempt investors, that any regulatory requirements had been met, and that Ms R had made her own decision to invest with knowledge of the risks. The ombudsman rejected that position. She found Hunter Jones breached FCA conduct rule COBS 4.7.7R by making a direct-offer financial promotion to Ms R when she should not have been certified as a sophisticated investor, and found no documentation evidencing an appropriateness assessment beyond a ticked questionnaire. Had appropriateness been adequately assessed, she found, Hunter Jones would have identified that Ms R had little investment experience and knowledge and that the loan notes, which she described as “complex, risky and specialist,” were not appropriate for her.

The ombudsman also found that Hunter Jones should have carried out due diligence on the Dolphin loan notes before promoting and arranging them. Citing a report contributed to the insolvency proceedings against Dolphin, she noted that the issuer had not published annual financial statements despite trading for a number of years, that a large percentage of its funds were being reserved to make payments to existing investors rather than for the renovation of properties, and that land charges were not always being arranged on property developments despite this being advertised. She acknowledged that the report did not exist at the time of the investments, but found that at least some of the issues would have become apparent earlier had due diligence been carried out, rejecting the argument that relying on it amounted to judging with hindsight.

The ombudsman upheld the complaint and ordered EFG to compensate Ms R by comparing the performance of her investments with a benchmark under which half is measured against the FTSE UK Private Investors Income Total Return Index and half against the average rate for one-year fixed-rate bonds published by the Bank of England, paying the difference between the fair value and the actual value. If the actual value is greater than the fair value, no compensation is payable. EFG must also pay Ms R £250 for the distress and upset caused, and interest of 8% simple per year applies from the final decision to settlement if the award is not settled within 28 days of the business receiving her acceptance. Ms R was required to accept or reject the decision by 18 June 2024.