Invalid Default Notices

[Basil Fawlty]

So what is the bottom line here? I have a disputed account with MBNA whereby I received a faulty DN (not enough days to remedy, incorrect amount, further compounded by being sold to EC before the remedy date, proof on SAR). Should I be accepting repudiation, and letting them take me to court, or, from reading this thread lately, should I give up and start thinking about contacting re working out a payment plan?

What would people on here do?

 

BF

[Bigdebtor]

BF

 

I would wait to see what happens in the Brandon appeal before doing anything further - unless you are being forced into earlier action?

 

OTHERS:

 

Can anyone update us on if/when such an appeal is being heard?

 

Also, if we have very old (2-3 years ago) invalid DN's and a TN issued (too) shortly after that, is there any TIME LIMIT (apart from the 6 year SB) on the OC now exploiting the current "get out of jail" card and re-issuing a valid DN several years later?

 

If the OC can do so in the above case - what is the situation if the debt has been assigned (or sold) to a DCA (but no valid NOA received) - who tried chasing up for a few months but now appears to have given up - nothing heard for about a year or more? Can the OC still re-issue a new valid DN? Can the DCA do so?

 

If no further payments have been made (thus accepting the TN on face value "by deed") - does that alter anything from above?

 

BD

Edited October 15, 2010 by Bigdebtor

[emandcole]

Fundamental Breach and Common Law right to claim repudiation - excerpts taken from STOCZNIA GDYNIA S.A. and GEARBULK HOLDINGS LTD.

 

The nature of the contract

 

1. The contract in the present case is one for the sale of future goods, in this case a vessel, to be constructed by the seller (the Yard) and delivered to the buyer (Gearbulk) by an agreed date. It contains many detailed provisions relating to the specification and performance of the vessel, as well as other matters. In relation to delay in delivery and deficiencies in speed, fuel consumption and deadweight capacity it provided for the payment of liquidated damages by the Yard and, if the delay or any of the deficiencies exceeded a certain level, ultimately gave Gearbulk a right to terminate the contract. The contract also gave the Yard a right to terminate it if Gearbulk failed to pay an instalment of the price when it became due.
   
2. The meaning of the word "terminate" depends on the context in which it is used. It is capable of meaning what is nowadays generally called rescission, that is, the discharge of all rights and obligations under the contract ab initio without liability on either side, and is also used in the context of discharge by frustration, but it is most commonly used in commercial contracts in the context of a right given to one party to a contract to treat it as discharged by reason of a breach on the part of the other.
   
3. It is inherent in the nature of a legally binding contract that each party expects to obtain the benefit of the bargain into which he has entered, or, if the contract is not performed, a right to recover compensation in the form of damages for the loss of that benefit.
   

The debtor expects to be able to pay the sums back over time, the lender allows this to happen as they recoup interest on the sums lent. The major benefit to the debtor is the right to pay the money back slowly, the major benefit to the lender is the accumulation of a greater sum than that originally lent.

Accordingly, in a case where one party's breach is such as, in the words of Diplock L.J. in Hongkong Fir Shipping Co. Ltd v Kawasaki Kisen Kaisha Ltd [1962] 2 Q.B. 26, to deprive the other of substantially the whole benefit which it was intended that he should obtain from the contract, the common law recognises the right of the injured party to treat the contract as discharged and to recover damages for the loss of the bargain. Such a breach is commonly described as "going to the root of the contract".

 

Would we all agree that the CCA affords the protection to the debtor to breach the agreement by not making a payment, or even a few payments before a DN is served?

 

Such a breach does not go to the heart of the contract, however the express failure to respond to the instruction and demand of the Default Notice (the last chance saloon) clearly is breaking the agreement in a major sense and certainly can be considered as ‘going to the root of the contract’.

The CCA does not state how many months can be missed before a DN is issued, however it is generally accepted that the length of the loan/agreement will provide a common sense guide to duration. A DN issued after 2 missed payments on an agreement lasting only 5 months is proportionally very fair in comparison to an agreement lasting 60 months when the lender issues a default after 6 missed payments. No sensible debtor could deny that level of fairness to the creditor.

 

That is all trite law, but it provides the underpinning, should it be required, for Mr. Boyd Q.C.'s submission that parties to a contract of this kind, or indeed to any contract, enter into negotiations in the expectation that if the one of them commits a breach which goes to the root of the contract in the sense just described, the other will be entitled to recover damages for the loss of his bargain. The parties may, of course, agree to depart from that position, but that is the point from which they start.

 

1. Whether a breach is sufficiently serious to go to the root of the contract depends on the terms of the contract and the nature of the breach, but it is open to the parties to agree that the breach of a particular term, however slight, is to be treated as having that effect and shall therefore entitle the other to treat the contract as repudiated.
   

Different words have been used to express that intention. The use of the word "condition" will usually (though not always – see Wickman Machine Tool Sales v Schuler (L.) A.G. [1974] A.C. 235) be sufficient, but many other forms of wording can be found. Sometimes the consequences of a breach are spelled out and sometimes they are not; in each case it is necessary to construe the contract as a whole to ascertain what the parties intended.

 

As we have learned from previous discussion in this thread the CCA does not appear to offer any advice regarding the outcome of a breach, it has been suggested that although the rights of either party may have been discharged the lender is still entitled to recover his funds and the debtor still obliged to pay the debt.

The above passage however appears to accept that one party is entitled to consider the agreement to be repudiated. If we look at the CCA and the arguments proposed to date it seems that the lender can, but isn’t actually entitled to, issue a termination letter to a debtor if the debtor did not respond to the demands of the Default Notice.

 

So, who breached the agreement first and who breached it in a manner that could be recognised as ‘going to the root of the contract’?

 

Yes, the debtor first creates a problem by failing to make the agreed payment. The Consumer Credit Act (Not Creditor Credit Act) provides breathing space for the debtor in this eventuality with the appropriate sections and the default process.

 

The lender, at a point of their reasonable choosing, is entitled to create a Default Notice compliant with the requirements of the CCA and they have had 36 years in order to understand the terms and expectations demanded by statute in order for that notice to be accepted as valid and in order for them to become entitled to issue and act upon subsequent notices of termination.

 

The lender creates his Default Notice and duly sends it to the debtor, the ‘pay up now or lose the rights’ (major benefit) of our agreement. If this DN is not complicit with regulatory intent wouldn’t it be fair to state that actually the first party breaching the contract in a way that ‘goies to the root of the contract’ is actually the lender?

 

1. Clause 5.8 in the present case gave the Yard the right to "terminate" the contract if Gearbulk committed a breach of contract by failing to pay an instalment of the price within fourteen days of the date on which it was due. If the Yard exercised that right, the terms of clause 5.9 gave it the right to recover the benefit of its bargain. Similarly, Articles 10.1-10.4 gave Gearbulk the right to "terminate" the contract if the Yard committed a breach of contract by failing to deliver the vessel within 150 days of the agreed date or by tendering it with deficiencies in capacity or performance which exceeded the limits below which the payment of liquidated damages was considered to be sufficient compensation.
   

 

In addition, Article 10.6 gave it the right to terminate the contract if the Yard committed a major breach which the Classification Society agreed would prevent it from completing and delivering the vessel by a specific date (the so-called "drop dead" date), or if it failed financially.

 

It is clear, and was not in dispute, that if either party exercised a right to terminate the contract pursuant to any of those terms, all obligations which remained for performance in the future would be discharged.

 

The nature of the circumstances giving rise to Gearbulk's right to terminate, therefore, was in all cases a serious breach by the Yard of its obligations and that, together with the provision for payment of liquidated damages for less serious breaches, provides a strong indication that if the right were exercised the parties intended that Gearbulk should have a right to recover any losses it might have suffered as a result of the loss of its bargain.

 

The nature and meaning of Article 10

 

1. All this may seem obvious, but it is important because it provides the background to the submissions made by Mr. Dunning Q.C. as to the meaning and effect of Article 10 as a whole and in particular its second (unnumbered) paragraph. His primary submission was that Article 10 contains a complete code which provides for the consequences of the various events with which it is concerned.
   

As such it displaces any right to treat the contract as repudiated at common law, leaving Gearbulk to the remedies for which it provided, namely, liquidated damages for delay and deficiencies in capacity and performance and the right to recover instalments of the price, with the benefit of a bank guarantee.

 

His alternative submission was that even if Article 10 does not exclude the right to treat the contract as repudiated at common law, it does provide an alternative means of bringing the contract to an end, but one which can be exercised only in accordance with its terms. In this case, he submitted, Gearbulk did not elect to treat any of the contracts as repudiated in accordance with the general law, but chose instead to exercise the rights of termination given by the contract itself. In those circumstances it cannot claim damages for the loss of its bargain because Article 10 does not provide for it to do so.

 

Does Article 10 displace the right to treat the contract as repudiated?

 

1. Mr. Dunning sought to derive support for the first of these submissions from the decision of this court in Lockland Builders v Rickwood [1995] 77 BLR 42.
   

In that case clause 2 of a contract for the construction of a house gave the building owner the right to determine the contract if the rate of progress, materials or workmanship proved unsatisfactory as certified by an independent third party and the building contractor failed to rectify them within a specified period.

 

The building owner was dissatisfied with the work, but did not seek to invoke clause 2. Instead he wrote to the building contractor purporting to treat the contract as discharged and sought to recover damages.

 

Is this similar to the Default process in the CCA? The lender has the right to use the Default process in order to secure future right to recover sums owed but messes the Default process up and terminates anyway.

 

The court noted that clause 2 was designed to deal with shortcomings of the very kind alleged and held that the common law right to treat the contract as discharged by reason of repudiation could arise only in a case where the breach was of a fundamental nature.

 

In effect clause 2 was designed to protect the builder from an unreasonable owner, allowing the builder to rectify any issues raised by the owner. The same protection is in place with the CCA, time to restore the agreement before a DN is issued, which if not met, constitutes a breach by the debtor that ‘goes to the root of the contract’.

 

Isn’t the debtor entitled to consider the invalid default notice and subsequent invitation/intention to terminate by the creditor, thus removing the major benefit to the debtor of the contract, as an act ‘going to the root of the contract’? Does this confirm the common law right to treat the contract as discharged?

 

The breaches alleged were not of that kind and so the building owner's only right to terminate arose under clause 2, which he had not invoked. In reaching its decision the court placed some emphasis on the fact that the clause was not expressed to be without prejudice to the building owner's rights under the general law.

 

So, the court held that as he had not invoked clause 2 of this particular agreement that the owner had no right to have terminated the contract, even though the owner had done this and taken the builder to court for damages.

 

This is comparable to a lender terminating an agreement (on the back of a faulty DN) when they had no right to as they did not take advantage of the CCA terms governing default and termination.

 

Whenever one party to a contract is given the right to terminate it in the event of a breach by the other it is necessary to examine carefully what the parties were intending to achieve and in particular what importance they intended to attach to the underlying obligation and the nature of the breach.

 

If you look at the summary for the Lockland Builders v Rickwood

[1995] 77 BLR 42 case it states that:

 

‘A contract for the construction of a house gave the building owner the right to determine the contract if the rate of progress, materials or workmanship proved unsatisfactory as certified by an independent third party and the building contractor failed to rectify them within a specified period. The building owner was dissatisfied with the work, but did not seek to invoke clause 2, but wrote to the contractor purporting to treat the contract as discharged and sought to recover damages’.

 

Held.

 

‘The clause was designed to deal with shortcomings of the very kind alleged and the common law right to treat the contract as discharged by reason of repudiation could arise only in a case where the breach was of a fundamental nature’.

 

‘The breaches alleged were not of that kind and so the building owner's only right to terminate arose under clause 2, which he had not invoked. The court placed some emphasis on the fact that the clause was not expressed to be without prejudice to the building owner's rights under the general law’.

 

This case appears to accept that there is a common law right to treat a contract as having been repudiated but vitally, the breach must be a fundamental one and not something of little importance.

 

Would it not follow that the failure of the creditor to issue a Default Notice compliant with the CCA which is then used to issue a written notice of termination removing the major benefit of the contract to the debtor (as they now want all of the money in one go) constitutes a breach that ‘goes to the root of the contract’?

 

The invalid Default Notice prejudices the protection the consumer has to provide remedy to the lender and prevent both removal of the major benefit of the contract, as well as the burden of having to meet the full payment for the debt.

 

Yes, the debtor missed payments but the lender has both duty and resource to issue that notice with precision and a failure to do that, that leads to the lender terminating the agreement (or acting as if the agreement has been terminated even if it is not technically available) with the removal of the major benefit must surely be assessed as being a fundamental breach.

 

As this is a fundamental, and not inconsequential breach of the terms surely the common law repudiation can be claimed?

 

In paragraph 88 of his judgment in Stocznia Gdanska S.A. v Latvian Shipping Co [2002] EWCA Civ 889, [2002] 2 Lloyd's Rep. 436 Rix L.J. expressed the view that where contractual and common law rights overlap it would be too harsh to regard the use of a contractual mechanism of termination as ousting the common law mechanism, at any rate against a background of an express reservation of rights. In this case I would go further.

 

In my view it is wrong to treat the right to terminate in accordance with the terms of the contract as different in substance from the right to treat the contract as discharged by reason of repudiation at common law. In those cases where the contract gives a right of termination they are in effect one and the same.

[pt2537]

so how do you overcome s170?

[pt2537]

170. No further sanctions for breach of Act.

— (1) A breach of any requirement made (otherwise than by any court) by or under this Act shall incur no civil or criminal sanction as being such a breach, except to the extent (if any) expressly provided by or under this Act.

[Bigdebtor]

PT

 

Why is the ending of the agreement and the capability to only recover arrears a SANCTION?

 

Surely it's simply a trade off

 

- no further credit allowed any more (on rolling credit agreement) by creditor

v arrears accrued to date (less damages) payable now by debtor ?

 

Also shouldn't NO SANCTION work both ways - nothing to detriment of debtor either? However a poor credit rating which goes unrepaired - possibly for years - is surely a sanction for the debtor?

 

Can you also comment on my earlier post about the dodgy TN being a clear expression of the creditor's desire to terminate which the debtor then agrees with - so agreement terminated by mutual consent?

 

BD

[bustthematrix]

I find it awfully curious just how much time and passion you are devoting to this PeterB...

[bustthematrix]

The Act also clearly states NO SANCTION CRIMINAL OR CIVIL but for that provided by the act, so i think you may struggle there, as the act does not allow acceptance of termination

 

We will know more when we get the Brandon appeal heard

True, but the Act does not bar acceptance of termination either. Nor does accepting termination necessarily qualify as a 'sanction' under the Act, IMO.

[pt2537]

True, but the Act does not bar acceptance of termination either. Nor does accepting termination necessarily qualify as a 'sanction' under the Act, IMO.

How the F**k can you accept something that is not available to the creditor?

[emandcole]

Still don't understand how statute technically preventing a creditor 'in a perfect world' from doing something is irrevelevant when the creditor has defaulted incorrectly and gone to the effort of terminating the contract.

 

Ok, termination isn't available and I get that, but how do we get round the fact that although this isn't available the creditor has demanded sums not yet due (as the agreement is live), in addition to depriving the major benefit of the contract to the debtor (bearing in mind the agreement is still live) and now has the poor sod in court who is likely confused by the cock up that is supposedly the creditor exercising their rights?

 

All of this and the creditor is allowed to do as they see fit under statute enacted to supposedly 'protect' the consumer from such cock ups? Completely unfair with the creditor then addressing their initial mess with the issue of a correct DN, seemingly whenever it suits, and suddenly everything is peachy?

 

No options for the debtor at all who is dragged through court wrongly as the creditor failed to default and terminate correctly in the order that then actually gives them the right to litigate?

[Bigdebtor]

PT

 

As I have said before - surely the creditor has expressed a DESIRE to terminate - so if the debtor agrees then it's ended by mutual agreement - so agreement over.

 

Surely it's not ILLEGAL for the creditor to terminate - he just can't do so unilaterally without either a valid DN or the debtor's agreement?

 

If the debtor then simply "grants his wish" then surely it;s agreement ended (by mutual consent) and the dodgy DN means the creditor can no longer claim the outstanding balance - only arrears less damages.

 

How can any law prevent the two parties acting as I've just said to end an agreement neither wants ton continue?

 

BD

[mot22]

So what if a debtor who is wholly unaware that the DN was dodgy and subsequent TN and demand for full payment were not allowed, responds to a demand for payment in full by paying that amount in full, and later becomes aware that the original demand was based on a dodgy DN, such that the termination and demand for full payment was "not allowed", can that debtor then request his full payment be returned ?

 

PS: I'm not being funny here.

If it is the contention that an OC can undo all of this termination and demand for full payment stuff all because of the word in the CCA "cannot"..then why would the debtor not be afforded the same right to undo his full payment?

Edited October 15, 2010 by mot22

[Bigdebtor]

Mot

 

Good point - sauce - goose and gander?

 

However I think you're probably making the same mistake as I seem to be making - using logic, common sense and fair play arguments - which the Law doesn't seem to recognise at all.

 

I have been making similar points for the last few days - but have had no answers yet.

 

I really can't believe this is how Bennion and Parliament meant it all to pan out some 36 years later - and I thought the judges had to interpret the words of the Act to mirror the "will of Parliament" - but no one has answered me yet to tell me whether I am right or not in this approach.

 

Good luck with your own crusades!

 

BD

[mot22]

Mot

 

Good point - sauce - goose and gander?

 

However I think you're probably making the same mistake as I seem to be making - using logic, common sense and fair play arguments - which the Law doesn't seem to recognise at all.

 

I have been making similar points for the last few days - but have had no answers yet.

 

I really can't believe this is how Bennion and Parliament meant it all to pan out some 36 years later - and I thought the judges had to interpret the words of the Act to mirror the "will of Parliament" - but no one has answered me yet to tell me whether I am right or not in this approach.

 

Good luck with your own crusades!

 

BD

Greetings Bigdebtor.

 

To be frank, I'm loathed to say anything that may be based on an opinion as I would not want to detract from any legal point that the very kind and generous members here help with. (not that I'm saying you are btw lol.

But it's obvious that the law is not only about fact but how one can mould facts to fit an argument.

The consequences to a debtor of this process of demands in full of payment have their consequences, which I am given to understand are not considered "duress" by the courts unless financial proven.

The consequences to the banks etc of having to return full payments that were "not allowed" (forgive me putting that in quote) would, no doubt give the banks etc cause for thought, assuming my "opinion" has any merit.

 

I'm rambling a bit I know, but perhaps some of the learned people here may be able to see how/if what I've asked can be factored into an argument about all this undoing of TN and demands for full payment that the banks etc are now trying to use against us.

Kind regards to all...

Edited October 15, 2010 by mot22

[Bigdebtor]

Mol

 

As I said - sauce - goose - gander!

 

If the Brandon appeal fails and the Banks can then "undo" any dodgy TN's, "unwind" and start all over again then your situation should follow on with a full refund of everything paid over - except the arrears then due - and you then start to pay the monthly amounts again (if you can afford to do so - otherwise more DN's, TN's etc).

 

This is the logical, fair, common sense consequence of what has been argued here - but will it be enforced?

 

I very much doubt it!

 

BD

[emandcole]

Given the fact that a default notice is now effectively redundant a creditor can essentially send you a letter before action whenever they feel like it and if you don't comply with their demand instigate litigation.

 

Come the day in court the creditor concedes they didn't issue a default notice 'as there's no real point in wasting the paper' but offers, if it pleases the court, to have the boys back at the office knock one up and fax it over. Judge happy, judgment granted, creditor happy, debtor screwed royally and CCA no longer fit for purpose.

 

Am I wrong?

[frettful38]

Mot

 

Good point - sauce - goose and gander?

 

However I think you're probably making the same mistake as I seem to be making - using logic, common sense and fair play arguments - which the Law doesn't seem to recognise at all.

 

I have been making similar points for the last few days - but have had no answers yet.

 

I really can't believe this is how Bennion and Parliament meant it all to pan out some 36 years later - and I thought the judges had to interpret the words of the Act to mirror the "will of Parliament" - but no one has answered me yet to tell me whether I am right or not in this approach.

 

Good luck with your own crusades!

 

BD

 

I think that the big secret is out of the bag....the secret being is that many of us are know more confident when we receive threats and letters from lenders and DCA's threatening court.....especially if we have a faulty DN and TN on top.

 

What we all though not too long ago, faulty DN, TN on top game over for creditor and all they were entitled too was the arrears. Well shocking as Clegg & Cameron have teamed up so have these lenders and the courts. They have caught on that people are able to fight by themselves with the help of forums like this and MSE, and they are not having that.

 

If we carry on like this then legal aid is already being pulled back and with people fighting their own lenders with their debts where are solicitors going to find work LOL. That is why their running this test case with Brandon to shut us all up once and for all like they did the refund bank charges case.

 

No one likes a smart ass monkey...especially a smart ass consumer/debtor monkey otherwise how will these lenders make a living. To them we are all like mushrooms

 

"KEEP US IN THE DARK AND FEED US SHIIIIIIIIIIIIIIIIIIIIIITE"

 

5000 posts and counting and still none of us know where we stand. They are always one step ahead of us, bit like prison break so what we have to do is block and corner them off and then get them with everything we got.

 

Sorry, been watching to many action movies today LOL!!!!!!!

Edited October 15, 2010 by frettful38

[Bigdebtor]

Fretful

 

I quite agree. I had hoped Vince Cable might have had a bit more gumption - and muscle - but he seems to have gone over to the dark side too!

 

- More old Etonians in Government now than in Harold Macmillan's time 50 years ago

- Banks flexing their muscles and seemingly now winning at every turn

 

Does anyone think there is any connection?

[frettful38]

And I thought that father christmas was real. Anyone know if it is or not?

 

I don't think the banks are flexing their muscles, more like pumping steroids LOL!!!!!!!

Edited October 15, 2010 by frettful38

[Bigdebtor]

If you're a UK Banker there are over 60 million Santas giving you 7000 million reasons to make THIS CHRISTMAS as wonderful as ever - otherwise - sorry - you've more chance of finding a humble or honest Banker!

 

BD

 

PS - Did you see them all quaffing their Krug at the recent masked ball in the City?

[emandcole]

If only we could systematically pick a bank, boycott it in every way and then move on to the next when it's on its knees. Will never happen - we'll all moan whilst paying money into it and as such we'll always allow them to retain the upper hand.

 

I trained in architecture and my industry is dead in the water - had I been a banker I would be loaded by now, safe in the knowledge that I can't put a foot wrong and that the tax payer will be forced to bale me out should I get myself into trouble.

 

If this was Korea we'd all assert our rights and go on a riot whilst attempting a coup to overthrow the tainted government. I guess now that tory boy Cameron is in power the bankers really will be having a fantastic Christmas ad infinitum.

 

Let's just queue up for our personal bar code tattoos and instruction leaflet on servitude now and have it done with

[alangee]

What happens to an account that has been "abandoned" by the OC and sold on?

 

My OH has an account where the OC has sent a statement and a letter stating that the "principal, interest and other fees have been abandoned", and after issuing a defective DN, has been sold on. My OH has informed the OC of the invalid DN, they have accepted that it is invalid, and have said that they will be recalling the account and issuing a new DN.

 

So what about the abandoned items? Are they then unabandoned (if there is such a word)? What happens to the OC's losses set against tax and possible insurance payments he received when he "abandoned" the account? All this is without the fact that my OH has had a default against her for the last three years, that should not have been entered as the DN was invalid.

 

Alan

[Bigdebtor]

If only we could systematically pick a bank, boycott it in every way and then move on to the next when it's on its knees. Will never happen - we'll all moan whilst paying money into it and as such we'll always allow them to retain the upper hand.

 

(

 

Emandcole

 

Totally agree! I thought there was a move afoot to set up a new basic simple "people's bank" which just held our money, lent us money at fair rates etc. - no casino operation etc. If this happens I for one will move straight over to it - leaving the current shower to "service" their own Eton alumni!

 

BD

[middenmess]

Emandcole

 

Totally agree! I thought there was a move afoot to set up a new basic simple "people's bank" which just held our money, lent us money at fair rates etc. - no casino operation etc. If this happens I for one will move straight over to it - leaving the current shower to "service" their own Eton alumni!

 

BD

 

If there's one thing that's certain it's that a Bank is a Bank is a Bank--leopards and spots comes to mind!

[rebel11]

If only we could systematically pick a bank, boycott it in every way and then move on to the next when it's on its knees. Will never happen - we'll all moan whilst paying money into it and as such we'll always allow them to retain the upper hand.

 

I trained in architecture and my industry is dead in the water - had I been a banker I would be loaded by now, safe in the knowledge that I can't put a foot wrong and that the tax payer will be forced to bale me out should I get myself into trouble.

 

If this was Korea we'd all assert our rights and go on a riot whilst attempting a coup to overthrow the tainted government. I guess now that tory boy Cameron is in power the bankers really will be having a fantastic Christmas ad infinitum.

 

Let's just queue up for our personal bar code tattoos and instruction leaflet on servitude now and have it done with

 

I've got a great plan, will it upset the banks? yes, would it be legal? yes, would people benefit? yes. This would be my personal strategy.