thanks

Is this far too long? 1. On 24 October 2014 ARROW GLOBAL LIMITED commenced proceedings against the defendant for £9320.78 plus interest, a debt allegedly incurred under a credit agreement between the Defendant and Citifinancial Europe. 2. However, the Claimant’s statement of case fails to give adequate information to enable me to properly assess my position with regards to the claim. 3. This claim appears to be for a Loanagreement regulated under the Consumer Credit Act 1974. 4. Except where otherwise mentioned in this Defence, I neither admit nor deny any allegation made in the Claimant’s Particulars of Claim and put the Claimant to strict proof thereof. 5. It is the Defendant’s belief that the last payment and acknowledgement on this account was over 6 years ago and accordingly considers the debt to be statute barred by virtue of Section 5 of the Limitation Act 1980. 6. It is deniedthat the Defendant has previouslyentered intoan agreement with the Claimantfor provision of credit. 7. The Defendant is embarrassed in pleading to the Particulars of Claim as it stands at present, inter alia: - 8. The claimants' particulars of claims disclose no legal cause of action and they are embarrassing to the Defendant as the claimant's statement of case is insufficiently particularised and does not comply or even attempt to comply with CPR part 16. In this regard I wish to draw the courts attention to the following matters; 9. The Particulars of Claim are vague and insufficient and do not disclose an adequate statement of facts relating to or proceeding the alleged cause of action. No particulars are offered in relation to the nature of the written agreement referred to, the method the claimant calculated any outstanding sums due, or any default notices issued or any other matters necessary to substantiate the claimant's claim. 10. The particulars of claim fail to state when the agreement was entered into. 11. A copy of the purported written agreement that the claimant cites in the Particulars of Claim, and which appears to form the basis upon which these proceedings have been brought, has not been served attached to the claim form. 12. Under Civil Procedure Rule 16.5 (4) where the claim includes a money claim, a defendant shall be taken to require that any allegation relating to the amount of money claimed be proved unless he expressly admits the allegation. Therefore it is expected that the Claimant be required to prove the allegation that the money is owed as claimed. 13. A copy of any evidence of both the scope and nature of any default, and proof of any amount outstanding on the alleged accounts, has not been served or attached to the claim form. 14. The Particulars of Claim are vague in that there is no agreement number. Consequently, it is proving difficult to plead to the particulars as matters stand. 15. Further to the case, on 29 October 2014 I requested the disclosure of information pursuant to the Civil Procedure Rules, which is vital to this case from the claimant. The information requested amounted to copies of the Credit Agreement referred to in the particulars of claim and any default or termination notices, a transcript of all transactions, including charges, fees, Notice of Assignment, interest, alleged repayments by myself and payments made by the original creditor. Also any other documents the Claimant seeks to rely on, including any default notices or termination notice required to give the claimant a legitimate right of action. 16. On the29 October 2014 the Defendant sent a request for inspection of documents mentioned in the claimants statement of case under Civil Procedure Rule 31.14 to Blake Lapthorn Solicitors. The Defendant requested the Claimant provide copies of the Agreement, Default Notice and Notice of Assignment . The request was sent by Royal Mail Recorded Delivery and was received and signed for on the 31 October 2014. 17. To Date the claimant has refused my request under the CPR and I have not received any such documentation requested. As a result it has proven difficult to compose this Defence without disclosure of the information requested. 18. On the 3 November 2014 the Defendant sent a formal request for a copy of the original agreement to Arrow Global Limited at their registered offices the address of which is on the Claim form, pursuant to section 78(1) of the Consumer Credit Act 1974 along with the statutory £1 fee. The request was sent by Royal Mail recorded delivery, and from the Royal Mail website, this letter has not yet been signed for. 19. Under Civil Procedure Rule 16.5 (4) Where the claim includes a money claim, a defendant shall be taken to require that any allegation relating to the amount of money claimed be proved unless he expressly admits the allegation. Therefore It is expected that the Claimant be required to prove the allegation that the money is owed as claimed. 20. At this stage without documentation I am unable to plead fully to the claim. I request the court orders the Claimants to provide the necessary documentation in order for me to fully plead my case else the Claim should stand struck out. 21. In the event that the relevant documents are received from the Claimants I will then be in a position to amend my defence, and would ask that the Claimants bear the costs of the amendment. 22. As things stand the Defendant denies the Claimant is entitled to claim the relief claimed or at all. 23. The courts attention is drawn to the fact that the without disclosure of the requested documentation pursuant to the Civil Procedure Rules I have not yet had the opportunity to asses if the documentation the claimant claims to be relying upon to bring this action even contains the prescribed terms required in Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) which was amended by Consumer Credit (Agreements) (Amendment) Regulations 2004 (SI2004/1482). The prescribed terms referred to are contained in schedule 6 column 2 of the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) and are inter alia: - A term stating the credit limit or the manner in which it will be determined or that there is no credit limit, A term stating the rate of any interest on the credit to be provided under the agreement and A term stating how the debtor is to discharge his obligations under the agreement to make the repayments, which may be expressed by reference to a combination of any of the following— Number of repayments; Amount of repayments; Frequency and timing of repayments; Dates of repayments; 24. The manner in which any of the above may be determined; or in any other way, and any power of the creditor to vary what is payable 25. The courts attention is drawn to the fact that where an agreement does not have the prescribed terms as stated in point 16 it is not compliant with section 60(1) Consumer Credit Act 1974 and therefore not enforceable by s127 (3). The courts attention is also drawn to the authority of the House of Lords in Wilson-v- FCT [2003] All ER (D) 187 (Jul) which confirms that where a document does not contain the required terms under the consumer credit act 1974 and the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) and Consumer Credit (Agreements) (Amendment) Regulations 2004 (SI2004/1482) the agreement cannot be enforced. 26. Notwithstanding points 16, 17 and 18, any such agreements must be signed in the prescribed manner by both debtor and creditor. If such a document is not signed by the debtor the document cannot be enforced by way of section 127(3) Consumer Credit Act 1974. 27. The claimant is therefore put to strict proof that such a compliant document exists. 28. It is neither admitted or denied that any Default Notice in the prescribed format was ever received and the Defendant puts the Claimant to strict proof that said document in the prescribed format was delivered to the defendant. 29. Notwithstanding point 21, I put the claimant to strict proof that any default notice sent to me was valid. I note that to be valid, a default notice needs to be accurate in terms of both the scope and nature of breach and include an accurate figure required to remedy any such breach. The prescribed format for such document is laid down in Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) and Amendment regulations the Consumer Credit (Enforcement, Default and Termination Notices) (Amendment) Regulations 2004 (SI 2004/3237) 30. Failure of a default notice to be accurate not only invalidates the default notice (Woodchester Lease Management Services Ltd v Swain and Co - [2001] GCCR 2255) but is a unlawful rescission of contract which would not only prevent the court enforcing any alleged debt, but would also give rise to a potential counterclaim for damages where damage occurs to my credit rating (Kpohraror v Woolwich Building Society - [1996] 4 All ER 119). 31. Without Disclosure of the relevant requested documentation I am unable to asses if I am indeed liable to the claimant, nor am I able to asses if the alleged agreement is properly executed, contain the required prescribed terms, or correct figures to make such an agreement enforceable by virtue of s127 Consumer Credit Act 1974 32. In view of the matters pleaded above, I respectfully request that the court gives consideration to whether the claimant's statement of case should be struck out as disclosing no reasonable grounds for bringing the claim, and/or that it fails to comply with CPR Part 16. 33. Alternatively, I respectfully request a stay in proceedings until such time as the claimant complies with the requests outlined in paragraph 22 above or until the court orders its compliance with the same. I will then be in a position to file a fully particularised defence and/or counterclaim and will seek the courts permission to amend my statement of case accordingly. 34. In addition it is drawn to the courts attention that schedule 3, s11 of the Consumer Credit Act 2006 prevents s15 repealing s127 (3) of the 1974 Act for agreements made before s15 came into effect since the agreement is alleged to have commenced in July 06 the Consumer Credit Act 1974 is the relevant Act in this case. 35. If the Claimant was not Citifinancial then it is not admitted that there was a lawful assignment. The Claimant is put to strict proof that the assignment was lawful and is put to strict proof that sufficient notice thereof was served upon myself. Without this proof the Claimant has no standing before the court. 36. The Law of Property Act 1925 is the relevant act that deals with the assignment of debts. Section 136(1) requires that for the assignment of a debt to be effective, express notice in writing must have been given to the debtor:- 36.1 Legal assignments of things in action. (a) Any absolute assignment by writing under the hand of the assignor (not purporting to be by way of charge only) of any debt or other legal thing in action, of which express notice in writing has been given to the debtor, trustee or other person from whom the assignor would have been entitled to claim such debt or thing in action, is effectual in law (subject to equities having priority over the right of the assignee) to pass and transfer from the date of such notice. (b) However, it is Section 196(4) that prescribes the requirements for giving sufficient notice by post:- 36.2 196. Regulations respecting notices. (a) Any notice required or authorised by this Act to be served shall also be sufficiently served, if it is sent by post in a registered letter addressed to the lessee, lessor, mortgagee, mortgagor, or other person to be served, by name, at the aforesaid place of abode or business, office, or counting-house, and if that letter is not returned [by the postal operator (within the meaning of the Postal Services Act 2000) concerned] undelivered; and that service shall be deemed to be made at the time at which the registered letter would in the ordinary course be delivered. (b) It is noted that by the Recorded Delivery Service Act 1962 a recorded delivery letter is equivalent to a registered letter and that under the Postal Services Act 2000 Schedule 8 any reference to registered post is to be construed as meaning a registered postal service (eg Royal Mail recorded delivery or special delivery). © For the assignment of a debt to be effective and so giving the Claimant a right of action a valid Notice of Assignment must have been sufficiently served on me using a registered postal service pursuant to s196(4) before proceedings were commenced. The Claimant is put to strict proof that any notice of assignment was sufficiently served on me before proceedings were commenced. Without this proof, the Claimant has no right of action. (d) Further, it is submitted that the mere fact of giving a notice does not, of itself, create an assignment and that there must be an actual assignment in existence. It is the actual Assignment, not just the Section 136 notice, under which the Claimant derives title to bring the claim and the Claimant is put to strict proof that such Assignment exists. It is further averred that I am entitled, in any event, to view the document of assignment as a matter of law (Van Lynn Developments v Pelias Construction Co Ltd 1968 [3] All ER 824) (e) It is further averred that to be valid the the alleged notice of assignment must accurately describe the assignment including the date (W F Harrison & Co Ltd v Burke & another [1956] 2 ALL ER 169). 37. At this stage without documentation I am unable to plead fully to the claim. I request the court orders the Claimants to provide the necessary documentation in order for me to fully plead my case else the Claim should stand struck out. 38. I respectfully ask the permission of the court to amend this defence and/or counterclaim when the claimant provides full disclosure of the requested documents. In the event that the relevant documents are received from the Claimants I will then be in a position to amend my defence, and would ask that the Claimants bear the costs of the amendment. 39. The Defendant also respectfully asks the Court to transfer these proceedings to the Colchester County Court. Thank you!

Yes it certainly is, as I would not pay an odd sum like that. I've had a copy of the signed CCA but no terms and conditions. No assignment from either Brittanica Recoveries or Arrow. Surely, it can't be legal for them to be suing me in another entity name?

Hi, I'm not sure about doing that as looking through some paperwork that Arrow sent, it's all their paperwork and information and it says last payment received on 11/2/2009 for an amount of £13.24. Whether this is accurate or not I don't know as it isn't any kind of statement, just a date on their file. It seems a very strange amount for payment that I would make in any event. I don't want to run the risk of submitting a defence on the basis of statute barred and then I find it isn't. What would happen if I submitted a defence on being statue barred and then I find it is not? I understand what you are saying that they don't know much but Arrow have sent me a copy of the CCA agreement without any terms and conditions other than key information and it seems to me that is all they have on file. I have previously asked for all records, and they sent some information that they hold, including my credit file. I also note from their information records that the owner is Britannica Recoveries S.a.r.l. - Atlas but Arrow are bringing the claim? Thanks for your help and advice.

Hi, yes the Particulars of Claim state nothing other than "the Claimant's claim is for the sum of £9320.78 being monies due from the Defendant to the Claimant under a regulated agreement between the Defendant and Citifinancial Europe plc and assigned to the Claimant. Notice of the assignment has been provided to the Defendant. The Defendant has failed to make payments in accordance with the terms of the agreement and a default notice has been served pursuant to the CCA 1974. AND the claimant claims the sum of GBP9320.78 TOGETHER with COSTS OF THIS CLAIM. Claimant Arrow Global Limited, Address for sending documents, Blake Lapthorn. No account number in the POA whatsoever. I am not confident in submitting a defence on SB basis as I can't be 100% of when I made the last payment, although I would recall 2008 but I don't have statements. Arrow Global Limited are the ones who are bringing the claim, but according to Citifinancial the debt was assigned to Britannica Recoveries S.a.r.l. How would this affect the claim, as it is another party who are bringing the claim. I have received a copy of the CCA agreement, uploaded earlier but have no terms and conditions. The only information on the CCA is key information and data protection stuff.

Ok, I understand re SB. There is no account reference anywhere in the claim. Its at work and will double check tomorrow

I wished I could find my old bank statements from the last statement I had from Citi was showing a payment no late 2006 before I lodged a claim about the PPI. I'm worried if I submit a SB defence, if and when it goes to court they can show it wasn't statute barred and as I'm a litigant in person it would be harder for me to defend this as I don't have the last statement. if I lodge a defence no NOA could I ask to re-amend defence and then change to statute barred. Also do these debt purchasing companies issued summons without the account number? Really feeling confused and don't know what to do

I have looked into the limitation act and pinsent masons definition of statute barred Contract l Within six years of the date of breach l The cause of action occurs as soon as the contract is breached. By contrast, in tort, no cause of action arises until all elements of duty, breach and damage are present l Unlike tort, the limitation period cannot be extended on latent damage grounds. I haven't made any payments to citi since 2007. I know from my credit record that CitiFinancial defaulted me in August 2008 and Arrow on the same date as Citi for the same debt about 3 years ago. the default came off my credit record in August this year as its now passed the six years. I would like to submit my defence on the debt being statute barred and if I do so, would I then be able to defend on other grounds too. I only ever had a letter from Citi saying they assigned the debt to Britannica recoveries S.a,r.l. in Luxembourg but arrow are saying it was then assigned from Britannica to arrow, no notice of assignments having ever been received. I would like to submit my defence next week. Thank you for your help

Would I have a defence for statue barred. I have not made any payments to this Citifinancial loan since 2007? thanks

Yes, and according to CitiFinancial assigned to Britannica recoveries but have never received any notice of assignments. No t&cs only that small piece of key information and data protection information. Is anyone able to help with my defence. Thank you

Also, the loan agreement number is not on the POC

Tried again and have managed to upload. Thanks for your help

I notice that is says "I understand that I am purchasing the product(s) ticked above on the credit provided by you and that the terms relating to the credit for the products can be found in clauses 1(a) and 5(a) in this agreement. I have never had, nor have they provided any terms and conditions other than the key information on the CCA.

Hi, shall I upload the agreement. To be honest, I am not sure if they have included all the T&C's. There is a section of key information after the breakdown and at the bottom it say's important - read this carefully to find out about your rights, (1) - (3) and then on the next page says if you want to know more about your rights under the Act, contact local trading standards department. The rest is Data protection, and the other pages are for the insurance they sold me and notes with that too. I have never had any separate terms, just that small section of key information. I will copy and upload

Hi, I received a copy of the CCA agreement yesterday. I did ask for loan A, B and C as they were ordered by the Ombudsman to re-write each loan as every time a balance was carried forward , it was incorrect in that the redemption included the PPI. I only received the current loan agreement from Arrow. No statements, no default notices and no assignments. From a letter from Citifinancial in 2008 they say the account was assigned to Britannica Recoveries S.a.r.l in Luxembourg and from the Arrow letter received yesterday Britannica Recoveries in Luxembourg have assigned to Arrow. I have never received any Notice of Assignments from either. I have received no statements or breakdown of payments made to the current agreement, and as the Ombudsman ordered Citifinancial to re-write the current agreement (plus the other 2 agreements) to ensure that the correct figures were carried forward, which they never did. I have a few days more to prepare a defence can anyone help and on what basis and I feel I want to make a counterclaim. I have spent so many years in correspondence Citifinancial and the Ombudsman on this. Also, when the ombudsman ruled about the PPI, as Citifinancial had sold me 5 different up front policies in total, they only paid up for 3 of them, and I have them to write to the Ombudsman again to re-open the case to have the other 2 dealt with, even though in their original decision they had to refund every single one. I have so much paperwork and it has taken up so much of my time and they do not want to seem to recalculate the loans to which the current agreement would have been a different amount. I haven't made any payments since late 2007 to Citifinancial. Thank you, your help is appreciated.

I have sent my CCA request to Arrow's registered address and having checked the royal mail website, no-one has signed for it as I assume this is just their formal address but that's the address on the summons so that's the one I will use. Looking back on my paperwork the last payments date back to late 2007

Do I need to send the CCA section 77 request to Arrow Global Limited Bedford Row address, which is the address on the summons?

Ok, thanks. I will get those off Monday. Last payment I believe in 2008

Any advice on drafting defence? thank you

Thank you. My replies are in blue Name of the Claimant ? Arrow Global Limited R/O,.20-22 Bedford Row, London WC1R 4JS Date of issue –24/10/2014 What is the claim for – the reason they have issued the claim: The Claimant’s claim is for the sum of £9320.78 being monies due from the Defendant to the Claim under a regulated agreement between the Defendant and Citifinancial Europe plc and assigned to the Claimant. Notice of the Assignment has been provided to the Defendant. The Defendant has failed to make payment in accordance with the terms of the agreement and a default notice has been served pursuant to the Consumer Credit Act 1974. And the Claimant claims the sum of £9320.78 TOGETHER with the costs of this claim. 2. 3rd October 2014. What is the value of the claim: £9320.78 (costs bring total to £9830.78) Is the claim for a current or credit/loan account or mobile phone account? LOAN When did you enter into the original agreement before or after 2007: Yes, as the final loan was consolidation of loan 1, and 2 which were new to change the interest rate but third loan (disputed loan) before 2007. Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. Not original creditor, but debt purchaser. Were you aware the account had been assigned – did you receive a Notice of Assignment? No. Only letter from citi saying it had been sold to Atlas but no Notice of Assignment. Did you receive a Default Notice from the original creditor? Can’t recall. Although a default was on my credit reference and that was removed on 30/8/2014 due to the six years. Have you been receiving statutory notices headed “Notice of Default sums” – at least once a year ? No Why did you cease payments:- Financial problems, big reduction in salary. Was there a dispute with the original creditor that remains unresolved? Yes. Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management[ plan? I did communicate with them, and try to resolve the dispute of the amount that was finally due after the PPI mis-selling. They were ordered by the Ombudsman to re-write each loan so that the third loan was correct and to put me back in a position had they not been sold.

Hi yes, claim form. I went online yesterday to lodge acknowledgment of service and notice of intend to full claim. Thank you

Hi, I have just been issued a claimform from Arrow Global Limited by their solicitors Blake Lapthorn. I have issued the acknowledgement of service and would very much appreciate some help and advice and how to defend this. Sorry history is quite long and apologise for this. In a nutshell, 1.Approached citifinancial in October 2005 for a loan of £10,000. Due to my credit history they were unable to offer £4,000 (or 4,000: cannot recall as I don’t have the paperwork and Citi have failed to provide this. It was at an extremely high rate and they sold me 2 different PPI policies, one for disability & insurance cover and one for takecare cover. I had pre-existing medical conditions and told them I did not need this as I had long term disability and sickness cover and life assurance through my employer. They advised that if I did not take the cover, the loan would not be approved. 2.Within a couple of months they rang to say I could now have the £10k and would give me a better interest rate. I went in to sign the paperwork and again they sold me another 2 policies. They were always up front policies with interest charged on them at the prevailing rate. I again reiterated that I did not need these policies but without them they could not proceed. I signed the paperwork and was not provided with a full redemption statement to show how they had arrived at the redemption figure bearing in mind I had paid up front PPI fees on 2 different policies. 3.3-4 months later, they rang again and said they could lower my interest rate but I need to complete a new loan form. I said I did not want to borrow any more money and if I wanted to lower the interest rate I had to add a small amount on, which I did. Again, they sold me 2 PPI policies, one disability and takecare cover and both added to the loan with interest. 4.The insurance application form attached to the third loan agreement is dated 21/7/2006 signed by me and witnessed by Citi, but I now notice that the CCA agreement is dated by Citifinancial 21/7/08. I also have a fax copy of the third loan agreement with a date of 1/9/2006 issued with an account. I am not sure why the loan agreement is dated some 2 years later by Citi. Maybe it’s their writing. 5.In early 2008 I complained to Citi about mis-selling so many up front policies that I did not need and had pre-existing medication conditions. They rejected my claim and I made a claim via the Ombudsman. 6.I lodged a complaint with the Ombudsman on 22/5/2008.In August 2009 the Ombudsman upheld my complaint and ordered Citi to put me back in a position had I not been sold the 6 PPI policies in total. They were also asked to re-calculate each loan on the basis these had not been sold, as the redemption figures carried forward to each new loan would have been different. Again, on the third loan which is the on-going dispute and which has been sold to Arrow was to be re-calculated on the basis of the new figures brought over to each loan and to also re-calculate the balance without those policies. 7.In early December 2009 Citi wrote to me with some calculations and a cheque for £3010.22 for a refund of the PPI premiums with interest. Their calculations were minimal and did not provide the new redemption figures and the new carried forward balances of each loan as instructed to do so by the Ombudsman. The PPI and Takecare cover premiums on the 3 loans were a total of £5102.05 and £2509.81 in interest, making a total of £7611.86 8.From that date on I have written to Citifinancial to ask for the full computations and calculations as it seems they only gave a breakdown as PPI refund due, plus interest and nothing else. They have not re-wrote each loan to reflect the totals without the policies and this in turn would have reduced the balance carried forward onto loan 2 and 3 and 3 being the loan still valid. 9.On 15/12/2009 I received a letter from Citifinancial saying I owed £10,194.46 10.Letter received 10 May 2012 from Citifinancial saying “some important news about your loan” transferred from Citifinancial to Britannia recoveries S.a.r.l. acting in the name on behalf of its compartment “Atlas” (Britannica-Atlas) and will be managed by Arrow Global Receivables Management Limited will take place on 21 May 2012. The transfer involves the assignment of all CitFinancial’s rights as lender to Britannica-Atlas who have agreed to perform the obligations of CitiFinancial under the terms of your Citi loan agreement. From May 2012 references to “we”, “us” “our”, “the Lender” and Citifinancial in your Citifinancial Loan agreement terms and conditions will become references to Britannica-Atlas and any references to the “group of companies” that include Cit will also become references to Britannica-Atlas. We are working closely with Arrow Global Receivables Management Limited to ensure a smooth transition of your account and they will be writing to you shortly to provide revised payment instructions. In the interim period, please continue to make payments in the usual way. 11.Letter received from Arrow Global receivables management limited is acting agent for Britannica recoveries S.a.r.l. – Atlas with Westcott Credit services dated 7 August 2012 with a statement from July 2011 to June 2012 showing a balance of £10,316.72. 12.Wrote to Westcott Credit services in August 2012 to advise Citifinal had not provided the information requested as per my SAR request, they had not re-written the loan as instructed to do so by the ombudsman. Also wrote in August and September to Arrow Global on 25/9/2012 for full SAR request. 13.Letter received from Arrow Global receiveables management Ltd Manchester saying an adjustment has been applied to your account so the balance was now £9320.78. 14.Letter Westcoff Credit Services dated 21/9/2012 balance of £9320.78 outstanding. 15.Letter dated 17/08/2012 from Citi saying Arrow will reply with SAR details and confirming I should write to Arrow Global Receivables Management Ltd in Manchester. 16.I then had to contact the Ombudsman again in 2012 as I became aware they had not reimbursed me for the Takecare policies as instructed to do so by the Ombudsman. The Ombudsman had to re-open the complaint, readdress the lack of full refund and on 1 November 2012 wrote to say it was correct, they had not refunded me for the Takecare policies and this would be forthcoming. Again, they could not provide the recalculated loan agreements as per the Ombudsman’s decision. I received a further £700 for these other 2 policies. 17. On 12/12/2012 I sent a letter to Arrow Global Receivables Management in Manchester for a SAR request with a £10.00 fee. They sent some information but nothing which I asked for. They sent me information that was more internal, a credit reference report In fact, minimal information. No statement, no notice of assignment and I have never received any notice of assignment. To be honest, I am not sure who owns the loan, Atlas or Global. The summons is from Global, but citi say it was sold to Atlas. 18.Letters continued to be sent to Arrow Global for the full SAR request but since nothing has been forthcoming. 19.Letter from Black Lapthorn dated 2/12/2013 saying they act for Arrow Global. Our client has purchased the debt and chasing payment. 20.Letter to Black Lapthorn dated 4/12/2013 saying I do not owe Arrow Global. I am still in dispute with Citi and still waiting for them to re-write the loans as per the Ombudsman’s instructions. 21.Letter Black Lapthorn dated 7/12/2014 saying I have submitted a data request but saying our client has received no such request but Arrow’s letter of confirming the £10.00 fee and the information was sent was worthless as it contained none of the documents I requested. They asked that I make another SAR request and send another £10.00. 22.Letter Arrow Global Bedford Row dated 3/9/2014 saying the notification of account transfer to new agency Black Lapthorn. 23.Letter 17/9/2014 to Blake Lapthorn stating I have never received any Notice of Assignment. I have sent a SAR request in 2012 along with Citigroup and Westcott breaching the regulations as they have failed to provide the documentation. I also state that I have already paid a £10 fee in this regard to Arrow. 24.Letter Blake Lapthorn dated 1/10/2014 saying we act for Arrow. Our client will reconsider suitable payments.If no reply within 14 days, they will issue court proceedings. This is now where I am up to with them, a court summons from Arrow Global, Bedford Row and their solicitors Blake Lapthorn. I am exasperated, exhausted and have spent some many hours of research and writing letters. I am prepared to defend in full and do not want to pay them another penny due to the constant harassment and total lack of consideration to provide me with the recalculations, and information requested by me and the instructions from the Ombudsman. Your help is very much appreciated and I can see it is a whole long history and I now find very confusing as to who actually purchased the debt as Citi say Atlas. I really don’t know where to start with my defence, I also want to consider a counterclaim against them for all the man hours, time and money I have spent on this just trying to get the data and information that I am entitled to. Thank you very much. J.

Is this the same Paul Lewis who was advocating and shouting from the rooftops about the new increased student fees to £9,000 were great and do not look at them as loans but a tax. I cannot believe that man saying student loans were great. My son is going off to uni this year and I can't tell you how worried I am and I feel our students have been sold down the river for a quick buck,. I wish you all luck with this new debt collector and string them out

Thanks for the update

There is something very funny going on, some directors having been directors of many other companies, now dissolved and so many name changes. They are trying to avoid something and why so much income and negative profit.