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  1. Ever since it was known that the government were intending to introduce the 'Interpleader/Third Party' provision into the new regulations it has been my personal opinion that this clause will lead to a significant number of complaints. I am more convinced than ever before of this. Most seriously was the fact that at the Consultation stage it was made very clear that an enforcement agent would only be able to charge a relatively modest sum (of £110) if goods were to be removed and that this fee would cover all costs including the removal through to the sale of vehicles (or household goods). It was a dreadful shock to discover months ago that enforcement agents would also be able to charge daily STORAGE fees for all goods removed. This was NEVER the intention at Consultation stage and MOJ confirmed that as a direct result of the introduction of the 'Third Party Interpleader' clause that it became necessary to apply STORAGE fees. In other words...all debtors will now be charged daily storage fees as a direct consequence of the introduction of a clause that should in effect on apply to a very small number of debtors !!! The introduction of daily storage fees will almost certainly lead to enforcement agents finding that the immediate removal of goods is financially very rewarding for the company. In the past few weeks I have written a number of urgent letters to the Ministry of Justice (and others) as I was aware from conversations with various enforcement companies that they would be looking at 'immediate removal' of goods given that the statutory regulations had been drafted in such a way so as to allow the 'sale fee' (of £110) to be applied to the account at the point when a bailiff 'attended to remove' (in other words..when a call has been made to the office to 'send a removal vehicle'. The current position under the regulations in force today is that this is referred to as an 'aborted van fee' (and highly questionable). Under the new regs, the charging of this fee would be LEGAL. It would seem that the enforcement industry themselves are now worried that what I had been highlighting for many weeks may well be about to happen !!! Below is a 'word copy' of an article that features in a trade magazine today.
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