"These two were repeatedly talking 4 per cent of the value of the pension funds."
Jurors were told that although the pair had created a system that kept them separate from their clients, Kelly was named as the financial adviser in most forms.
"Most of the people had never heard of him prior to discovering what had gone wrong," said Fenhalls.
"Their dealings were all with the introducers.
"The pension holders were cold-called on the phone.
"There is nothing wrong or unlawful about cold calling, so long as the people who are doing it got the information legitimately.
"Most of the people who received these phone calls formed the impression from the calls they got that their current pension holder, usually Equitable Life, provided their details."
The impression that their current pension provider had handed over their information properly lent a level of confidence in the scheme.
To hide the fraudulent nature scheme, the Sipp was being regulated by Hornbuckle Mitchell, a company that relied on the "integrity and competence" of PCD.
To regulate the financial adviser aspect, Kelly and Nicholls chose an offshore Cypriot company rather than a UK-based regulator.
During the trial an elderly and blind victim, Dennis Mountford, told jurors he was tricked into transferring his pension into a high-risk scheme after he signed forms he could not read.
Kelly, of Wilmslow, Cheshire, denied but was convicted of conspiracy to defraud and transferring criminal property, namely commission payments from pension holders, between July 2008 and December 2012.
Nicholls, of Bromsgrove, Worcestershire, denied but was convicted of conspiracy to defraud and transferring criminal property, namely commission payments from pension holders, between October 2008 and March 2015.
Court Report
