One notable transaction among these actions was their role as advisors to the government on the sale of New Zealand Rail Limited to overseas interests; a deal in which Fay and Richwhite later bought 31.8 per cent of the shares, and were subsequently investigated for insider trading by NZ authorities.
In October 2004 the New Zealand Securities Commission accused Richwhite and Midavia Rail Investments, a company owned by Richwhite and Fay, of insider trading.