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Invalid Default Notices


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this is just my view on it all

 

I agree personally. Surely any claim of this nature should actually focus on ascertaining the rights of the parties involved. If the court agrees the account is still live (as you might maintain if they reject your defence of repudiatory breach) then they'd need to have issued a fresh DN.

 

Problem for them here is that they have to maintain the account is terminated all the way to the hearing (if it is not they were not allowed to litigate for the full balance) and as it is indeed terminated they are also prevented from issuing another 'correct' DN on the terminated account.

 

If the court declares the account to be live then surely the claim in its present format needs to be ended and re-started, this time after the creditor has issued a correct DN, terminated, LBA and then re-claimed. If you've submitted a defence however to the same claim before then surely they'd need the permission of the court to litigate for the same account?

 

In effect if a creditor litigates and subsequently the account is declared live are they not shooting themselves in the foot having taken it to court already for the same alleged consumer breach? It is after all they who have messed the CCA process up and not you.

 

First line of defence then perhaps would be to claim repudiatory breach as the main benefit of the contract (you paying by monthly installments) has been revoked. This also evidences an element of prejudice as the action of the creditor in demanding the full balance placed undue stresses and burden on the consumer.

 

In the Amex v Brandon case a significant contributory factor leading to the final conclusion of the judge was that the consumer has suffered no prejudice. Therefore, make sure prejudice is key to your defence. An invalid DN on your credit file also adds to the prejudice suffered.

 

If this first line of defence fails and the court rejects the repudiatory breach angle then the account is declared as still being live. The creditor (under the belief the account is terminated or they had no place litigating in the first place for the full balance) has to run with the original DN as they are prevented from issuing a second or third correct DN once the account is terminated.

 

This surely prevents them from conjuring up a replacement DN to excuse the original they used to litigate on. I don't see how the creditor, once a DN is examined in court, can be allowed to 'go and get another one' if their original is impaired.

 

Bit like being the first to hit the answer button in a quiz show and then getting the answer wrong. You'd expect the quiz host to turn to the other contestant for the answer, not ignore the other contestant and allow the original another chance to go on the internet, research the question and then give the correct answer to win the show. Allowing the creditor to 'go and find another DN that is valid' seems comparable to this and is wholly unfair to the consumer.

 

If therefore the account is live and the original DN is found to be invalid the claim surely cannot succeed? This then forces the creditor to discontinue or for the court to find in favour of the consumer. As the claim has already been brought and the claimant lost they are surely prevented from litigating again and the consumer wins.

 

Key to this then for the creditor is to be absolutely certain the DN is valid before terminating. That way they should have little reason not to beat the consumer, assuming all of the other issues they normally mess up have been correctly worked.

 

How does this all sound and where do we disagree here?

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I agree personally. Surely any claim of this nature should actually focus on ascertaining the rights of the parties involved. If the court agrees the account is still live (as you might maintain if they reject your defence of repudiatory breach) then they'd need to have issued a fresh DN.

 

yes they need a new DN

 

Problem for them here is that they have to maintain the account is terminated all the way to the hearing (if it is not they were not allowed to litigate for the full balance) and as it is indeed terminated they are also prevented from issuing another 'correct' DN on the terminated account.

 

If the court declares the account to be live then surely the claim in its present format needs to be ended and re-started, this time after the creditor has issued a correct DN, terminated, LBA and then re-claimed. If you've submitted a defence however to the same claim before then surely they'd need the permission of the court to litigate for the same account?

 

In effect if a creditor litigates and subsequently the account is declared live are they not shooting themselves in the foot having taken it to court already for the same alleged consumer breach? It is after all they who have messed the CCA process up and not you.

 

Ii they get to the court and it is not terminated then they SHOULD lose as they had no right to bring the claim on the back of a dodgy DN.

but now you will have to argue why they cant issue a new default notice and start again.

 

If they get to the Hearing and in fact it is terminated then they SHOULD lose as they haven't complied with the CCA on the DN issue.

 

First line of defence then perhaps would be to claim repudiatory breach as the main benefit of the contract (you paying by monthly installments) has been revoked. This also evidences an element of prejudice as the action of the creditor in demanding the full balance placed undue stresses and burden on the consumer.

 

In the Amex v Brandon case a significant contributory factor leading to the final conclusion of the judge was that the consumer has suffered no prejudice. Therefore, make sure prejudice is key to your defence. An invalid DN on your credit file also adds to the prejudice suffered.

 

Parliament has made the rules that must be folowed in respect of the DN, this judge has decided that he doesn't have to follow them

 

If this first line of defence fails and the court rejects the repudiatory breach angle then the account is declared as still being live. The creditor (under the belief the account is terminated or they had no place litigating in the first place for the full balance) has to run with the original DN as they are prevented from issuing a second or third correct DN once the account is terminated.

 

if the account is declared live it doesn't matter that he thought it was terminated,

if its live then he Can go away and issue a new DN

 

 

This surely prevents them from conjuring up a replacement DN to excuse the original they used to litigate on. I don't see how the creditor, once a DN is examined in court, can be allowed to 'go and get another one' if their original is impaired.

 

If the account is still live they can

 

Bit like being the first to hit the answer button in a quiz show and then getting the answer wrong. You'd expect the quiz host to turn to the other contestant for the answer, not ignore the other contestant and allow the original another chance to go on the internet, research the question and then give the correct answer to win the show. Allowing the creditor to 'go and find another DN that is valid' seems comparable to this and is wholly unfair to the consumer.

 

If therefore the account is live and the original DN is found to be invalid the claim surely cannot succeed? This then forces the creditor to discontinue or for the court to find in favour of the consumer. As the claim has already been brought and the claimant lost they are surely prevented from litigating again and the consumer wins. a good point

 

Key to this then for the creditor is to be absolutely certain the DN is valid before terminating. That way they should have little reason not to beat the consumer, assuming all of the other issues they normally mess up have been correctly worked.

 

How does this all sound and where do we disagree here?

 

 

judges lately are going against technical challenges and interpreting the rules to suit

just my opinion.

 

wp3

Edited by welshperson3
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Hi

 

THe faulty dndoes not remove the entitlement to recover unpaid amounts , where does section 87 say that. No it removes his entitlement to terminate.

 

peter

 

CCA appears to be very clear on this point, as below;

 

87-( 1 ) Service of a notice on the debtor or hirer in accordance with section 88 (a " default notice ") is necessary before the creditor or owner can become entitled, by reason of any breach by the debtor or hirer of a regulated agreement,-

 

(a) to terminate the agreement, or

(b) to demand earlier payment of any sum, or

© to recover possession of any goods or land, or

(d) to treat any right conferred on the debtor or hirer by the agreement as terminated, restricted or deferred, or

(e) to enforce any security.

 

Therefore the OC must comply with s88 before seeking "earlier payment of any sum" (ie, monies as yet unpaid).

 

Hope that helps.

 

LA

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Hi

 

THe faulty dndoes not remove the entitlement to recover unpaid amounts , where does section 87 say that. No it removes his entitlement to terminate.

 

peter

 

If a faulty DN removes the entitlement to terminate but the creditor goes ahead and ceases to perform, his actions surely become repudiation.

 

PS in your earlier post: you said default termination is common law. Credit agreements are regulated by CCA. this is unavoidable therefore a default termination is CCA law (as permitted). Only repudiation following an unlawful termination would come under common law.

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For me, the fact is that the two parties to the credit agreement/contract [have] agreed that the contract and the relationship is at an end (terminated), so a defective Default Notice only prevents the creditor in succeeding with his claim for the full balance on the (now terminated) agreement/contract, the said notice does not invalidate the agreed ending of the credit agreement, if 'consensus ad idem' can be shown, that is, the two parties are in agreement to the [same] thing (the ending/termination), then the Courts have no right to declare that the law does no recognize such an agreement between the two parties, the defective Default Notice cannot (in my opinion) be used to justify that the credit agreement endures, not in these such circumstances.

 

The Court would be reinstating the credit agreement and ignoring the rights of both parties and depriving the debtor of a defence that is complete in law and that can only be described as ABSOLUTELY UNJUST.

 

Yes I know the CCA 1974 (as amended) the legislation thereof that applies to the service of a DN and the creditor's entitlement (if he complies with that prescribed language) states that he (the creditor) is not entitled to this action if he does not comply with that said legislation, however, if he has not complied and he does proceed with this action, the defective Default Notice (if that is the case) does not undo what he has done, and the only persons who can undo it are the two parties to the agreement/contract - the creditor and the debtor.

 

These cases need to be defended so that there can be a significant amount of case law on this subject based on the circumstances of each case of this type and then and only then will we all know where we stand and where we fall.

 

Kind Regards

 

The Mould

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You cannot say that a creditor can do something that the statute prohibits. The lender cannot terminate unless he complies with the requirements of s87-89, and s89 is clear that where a breach is remedied the breach is not to have occurred.

 

I do not see that the lender can step outside of the statute and do something which is contrary to the will of parliament. it really is clear cut, the way counsel has explained it.

But in fact this is precisely what the creditors do do. They cease to perform on a contract that by statute could not have been terminated.

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The judge in my case pointed out that if the DN was invalid ( he didnt actually say it was ) it merely meant that the termination was invalid so the agreement was still valid and the money was still owed.

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I would love to hear what others would have done in my case, here is a summary.

 

1. Faulty DN received.

2. Account terminated

3. Claim issued for repo of vehicle

3. Claimant changes dates on DN despite having lodged the original in their statement of truth.

4. Judge says date 'clerical error' and allows repo, despite my vigorous defence.

5. No point in appealing the repo as I didnt want it anyway, and even if I had they could still have then claimed the money as I had only appealed the repo.

6. Claimant decides they dont want to repo and apply to the court for a conversion to money order.

7. Judge allows this as they don't have to take the vehicle if they dont want it. Little point in appealing as they have done nothing wrong.

8. Too late to appeal the original order as the timescale has passed.

 

So despite having a DN that the claimant knew was invalid and the judge didnt care if it was or not, it was impossible to win.

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The judge in my case pointed out that if the DN was invalid ( he didnt actually say it was ) it merely meant that the termination was invalid so the agreement was still valid and the money was still owed.

 

This is appalling cosalt.

 

As many here have said, a defective DN removes full entitlement to remedy a breach. If a defective DN is presented in court, as it was with you, and a court decide in favour of the OC, then it automatically breaches s89;

 

89. If before the date specified for that purpose in the default notice the debtor or hirer takes the action specified under section 88(1)(b) or © the breach shall be treated as not having occurred.

 

The point being that the DN is an opportunity (a last opportunity) for the debtor to put things right as though the breach never occured. This situation cannot happen where the OC sues the debtor using as his basis a defective DN, as it would of necessity require the debtor to undergo the extreme stress of being sued.

 

This is why, IMO, a second DN cannot be issued as it would be a further breach of s89 and, even if a court declared that the agreement was still 'active', the OC would (or should) be powerless to act due to having to deliberately breach s89 in order to terminate the agreement and recover money/goods. Were the OC to do this and get his actions sanctioned by a court, then it is clear that CCA no longer exists to protect consumers.

 

LA

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Hi

 

A hypothetical situation.

 

An agreement is entered into for a credit card, the T and cs have the usual clause, which says that the agreement may be terminated at any timer ny either party and on that termination all amounts become due and payable.

Some time down the line the debtor defaults on repayments, after the usual round of warning letters the creditor defaults the account with a notice under section 87 of the act.

The debtor does not remedy and the creditor terminates the agreement and commences court action to recover liabilities under the contract.

The debtor then realises that the default notice did not correctly state the amount necessary to remedy the breach, so as a defence he says that the court was not “entitled “ to terminate and demand early payment by breach of the agreement as they had not filled the requirement of section 87.

The decision faced by the court is one of deciding whether the creditor was or was not entitled to take enforcement action or whether they were prevented from doing so by the requirements of the consumer credit act.

If the court decides they are then the proceedings continue, if not then the creditor is not entitled to enforce and the case is thrown out and the creditor has to re issue a default and re file.

This may seem to be simplistic and it is, but I think this is as far as a situation like this will go in reality.

However just for interest lets say that the debtor counter litigates on the grounds that the creditor has tried to demand early payment on the account, when the court has ruled that the agreement has not been terminated because of a defected DN.

I think there are Four problems here.

 

First The Dn wa not valid so niether is the termination or the rest of the enforcement , so the agrement is still live and nothing stopping the credior from issuing a new default.

Second, if this “termination by breach” was not an entitlement of the creditor then neither was the option to demand ealy payment.

Third. Seeking to terminate or demand early repayment is not a breach of the act. It cannot be, the facility to terminate the agreement and demand payment is mentioned in the contract, the act does not prohibit it. This was what was confirmed in Brandon.

Thinking about this there is no reason why they cannot demand early payment of the loan because the agreement is terminated, the terms governing repayment do not apply, it does not mean of course that they can enforce that demand any more that a creditor can enforce a demand for payment when it is in breach of 127(3).

Lastly. The contract has already been breached by the debtor , this fact was also repeatedly raised by the judge in Brandon when he says no one has reputed the fact that the debtor breached the agreement.

The issuance of a fault DN does not erase the fact that the contract has been breached, the breach has not been remedied, the creditor has the right under common law to sue for damages or the liabilities under the contract.

Best regards

Peter

Edited by Dodgeball
spelling

DO NOT PAY UPFRONT FEES TO COLD CALLERS PROMISING TO WRITE OFF YOUR DEBTS

DO NOT PAY UPFRONT FEES FOR COSTLY TELEPHONE CONSULTATIONS WITH SO CALLED "EXPERTS" THEY INVARIABLY ARE NOTHING OF THE SORT

BEWARE OF QUICK FIX DEBT SOLUTIONS, IF IT LOOKS LIKE IT IS TO GOOD TO BE TRUE IT INVARIABLY IS

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From reading between the lines on all these posts i would say that defending a claim - solely on a dodgy DN - is a bit of a lottery.

 

But a dodgy DN in support of other dodgy paperwork - or in conjunction with other arguements may add weight to how your case is viewed.

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From reading between the lines on all these posts i would say that defending a claim - solely on a dodgy DN - is a bit of a lottery.

 

But a dodgy DN in support of other dodgy paperwork - or in conjunction with other arguements may add weight to how your case is viewed.

 

HI

 

If you are talking about using this as a means of getting out of repying your loan in would go further i would say it is a none starter.

 

However if you use sectuion 87 as it is meant to be used, it provides a degree of consumer protection, in that the debtor is given the correct clear information and time in order to remedy.

 

Peter

DO NOT PAY UPFRONT FEES TO COLD CALLERS PROMISING TO WRITE OFF YOUR DEBTS

DO NOT PAY UPFRONT FEES FOR COSTLY TELEPHONE CONSULTATIONS WITH SO CALLED "EXPERTS" THEY INVARIABLY ARE NOTHING OF THE SORT

BEWARE OF QUICK FIX DEBT SOLUTIONS, IF IT LOOKS LIKE IT IS TO GOOD TO BE TRUE IT INVARIABLY IS

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An agreement is entered into for a credit card, the T and cs have the usual clause, which says that the agreement may be terminated at any timer ny either party and on that termination all amounts become due and payable.

Some time down the line the debtor defaults on repayments, after the usual round of warning letters the creditor defaults the account with a notice under section 87 of the act.

The debtor does not remedy and the creditor terminates the agreement and commences court action to recover liabilities under the contract.

The debtor then realises that the default notice did not correctly state the amount necessary to remedy the breach, so as a defence he says that the court was not “entitled “ to terminate and demand early payment by breach of the agreement as they had not filled the requirement of section 87.

The decision faced by the court is one of deciding whether the creditor was or was not entitled to take enforcement action or whether they were prevented from doing so by the requirements of the consumer credit act.

 

This is the Woodchester scenario, where the judge ruled that a DN must state the correct amount.

 

If the court decides they are then the proceedings continue, if not then the creditor is not entitled to enforce and the case is thrown out and the creditor has to re issue a default and re file.

 

The OC would only be able to re-issue a compliant DN by breaching s89, as at this stage it is not possible to set the position to how it was before the breach. The debtor has already had a court action erroneously thrown at him.

 

However just for interest lets say that the debtor counter litigates on the grounds that the creditor has tried to demand early payment on the account when the court has ruled that the agreement has not been terminated on breach of the agreement because of a defected DN.

I think there are Four problems here.

 

First The Dn wa not vlkid soi niether is the termination or the rest of the enforcement , so the agrement is still live and nothing stopping the credior from issuing a new default.

 

If it is live but the OC has either taken the matter to court and/or recovered goods, then he has done so in breach of the contract and of the Act. It's all very well saying that the agreement is still 'live', but when the OC with all its legal muscle tells a lowly debtor that the agreement is at an end and then takes the poor sod to court, there is little doubt that the agreement is dead. Moreover, no contract can exist where both parties want it ended - basic contract law - and if the debtor has accepted the OC's termination, then that concludes the contract. As The Mould has said, no contract can be forced upon two parties who have previously agreed to end it.

 

Sedcond if this “termination by breach” was not an entitlement of the creditor then neither was the option to demand ealy payment.

 

Yet he demanded earlier payment nevertheless, and even took the debtor to court!

 

Third. Seeking to terminate or demand early repayment is not a breach of the act. It cannot be, the facility to terminate the agreement and demand payment is mentioned in the contract the act does not prohibit it. This was what was confirmed in Brandon.

Thinking about this there is no reason why they cannot demand early payment of the loan because the agreement is terminated, so the terms governing repayment do not apply, it does not mean of course that they can enforce that demand any more that a creditor can enforce a demand for payment when it is in breach of 127(3).

 

It is a breach of the Act when s88 is not complied with, and this is clearly stated at s87. Yes, the OC can terminate the agreement but the Act is the last word here and it states that termination on breach must be preceeded with a DN that complies with s88.

 

Lastly. The contract has already been breached by the debtor , this fact was also repeatedly raised by the judge in Brandon when he says no one has reputed the fact that the debtor breached the agreement.

The issuance of a fault DN does not erase the fact that the contract has been breached, the breach has not been remedied, the creditor has the right under common law to sue for damages or the liabilities under the contract.

 

Yes, the debtor breaches the contract but, by issuing a defective DN, the OC breaches both the contract (it is regulated by the Act) and the Act itself (at s88, and s89 if it goes to court).

 

I remain seriously puzzled why creditors are unable to get this simple document right and why there is so much debtor-bashing when complaints about defective DNs are made. Some of the DNs are impossible to comply with, giving insufficient time or demanding far too much money. I also do not understand why the Woodchester judgement is so systematically ignored, when it sets a precedent for reliance on correctly-formatted DNs.

 

LA

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HI

 

If you are talking about using this as a means of getting out of repying your loan in would go further i would say it is a none starter.

 

peter i would agree with this for the simple fact that judges are not sticking to the word of the law.

they are saying that a invalid DN means nothing as the debtor suffered no detriment.

they are looking at it as (you borrowed the money so you should pay it back) then they interpret the law to fit.

 

However if you use sectuion 87 as it is meant to be used, it provides a degree of consumer protection, in that the debtor is given the correct clear information and time in order to remedy.

 

Peter

 

 

on a point of law then there is a good argument, but the hardest point is convincing a judge that he has to stick to the law as laid down by Parliament.

 

if he does then may be it is unfair on the creditor as the debtor gets out of paying on a technical breach.

and this is what is happening he is not allowing debtors to get out of paying on a technical breach.

 

anyone that takes this on is going to have there hands full.

 

 

wp3

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The courts and the government are looking at fairness rather than technical breaches.

this can be seen in the amendments to the CCA in 2006 they removed s127 of the CCA which says

 

 

The court shall not make an enforcement order under section 65(1) if section 61(1)(a) (signing of agreements) was not complied with unless a document (whether or not in the prescribed form and complying with regulations under section 60(1)) itself containing all the prescribed terms of the agreement was signed by the debtor or hirer (whether or not in the prescribed manner).

 

 

and this was added to the CCA

 

 

140AUnfair relationships between creditors and debtors

 

(1)The court may make an order under section 140B in connection with a credit agreement if it determines that the relationship between the creditor and the debtor arising out of the agreement (or the agreement taken with any related agreement) is unfair to the debtor because of one or more of the following

 

 

my point is that government and courts don't like technical challenges of the agreements which can also be seen in the OFT guidance all to do with fairness

 

s127 CCA was all about tecnical breaches its gone now but why ?

 

there are good points of law to show that a dodgy DN is fatal to the creditors agreement but how the judge views it is a different matter.

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So are we not again left with the situation where we have to provide a positive assertion as to how this was detrimental to us. i.e. I had the funds available in x account (see this statement) Had bank x allowed me more time to remedy this breach then I would have paid the balance owing and the account would have continued. By not allowing me the opportunity to remedy the breach bank x issued a invalid default notice. They later informed me this account had been Terminated and I have accepted this so although the Default Notice did not affect the account or the money due bank x in effect Terminated this account with no notice whatsoever and are not entitled to take the next step which would be enforcement.

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This is the Woodchester scenario, where the judge ruled that a DN must state the correct amount.

 

 

 

The OC would only be able to re-issue a compliant DN by breaching s89, as at this stage it is not possible to set the position to how it was before the breach. The debtor has already had a court action erroneously thrown at him.

 

 

I honestly so not understand this.

Issuing an incorrectly calculated DN does not cure the breach. Section 89 says if the actions are taken to remedy, then the breach is cured. The actions have not been taken so the breach still exists. It can be argued that the correct information has not been given , if this is the case the court will throw the case out. But I do ot see why the creditor cannot just recalculate and re issue the claim. The debtor has not had a case erroneously thrown at him he did breach, that is not in question, the enforcement has just been halted because he has not been given the correct information or time to remedy.

 

If it is live but the OC has either taken the matter to court and/or recovered goods, then he has done so in breach of the contract and of the Act. It's all very well saying that the agreement is still 'live', but when the OC with all its legal muscle tells a lowly debtor that the agreement is at an end and then takes the poor sod to court, there is little doubt that the agreement is dead. Moreover, no contract can exist where both parties want it ended - basic contract law - and if the debtor has accepted the OC's termination, then that concludes the contract. As The Mould has said, no contract can be forced upon two parties who have previously agreed to end it.

 

This is true in fact the debtor can unilaterally cancel the contract if he likes but it does not remove the liabilities due under the contract or the common law rights of the creditor to reclaim them

It is for the court to decide if the DN is valid or not, they will then decide if the creditor had the right to terminate, in order to make that ruling the court would have to have the argument in front of them, in order for that to happen the creditor must be able to terminate. The court will not sanction the creditor for doing what is necessary in order to enforce.

 

 

Yet he demanded earlier payment nevertheless, and even took the debtor to court!

 

what other actions co0ould they take in order to enforce?

 

 

 

It is a breach of the Act when s88 is not complied with, and this is clearly stated at s87. Yes, the OC can terminate the agreement but the Act is the last word here and it states that termination on breach must be preceeded with a DN that complies with s88.

 

 

Agree but it is curable breach all it needs is for the creditor to issue a corrected default,

There is nothing that says by issuing an incorrect default the creditor looses the rights to his money.

Yes, the debtor breaches the contract but, by issuing a defective DN, the OC breaches both the contract (it is regulated by the Act) and the Act itself (at s88, and s89 if it goes to court).

 

NO he doesn’t he breaches a requirement of the act which means the creditor is not entitled to take proceedings to recover liabilities due under the contract.

 

 

I remain seriously puzzled why creditors are unable to get this simple document right and why there is so much debtor-bashing when complaints about defective DNs are made. Some of the DNs are impossible to comply with, giving insufficient time or demanding far too much money. I also do not understand why the Woodchester judgement is so systematically ignored, when it sets a precedent for reliance on correctly-formatted DNs.

The swain case quite correctly found that the ineffective default required that the debtor was reimbursed for monies paid under the incorrect notice. That is all it did, it did not say that the debtor can avoid any of the debt owed, it did not invalidate the contract, nothing is said about what happened to the contract after the judgement nor should it it was not the point at issue. We all know that an effective default is necessary before enforcement, it is not an issue what is being said on here is that the secondary effect of this error is that the contract and more importantly the liabilities under the contract are somehow lost because of this, this is not what the Swain case showed at all nor would itegaards

peter

LA

 

see above

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The courts and the government are looking at fairness rather than technical breaches.

this can be seen in the amendments to the CCA in 2006 they removed s127 of the CCA which says

 

 

The court shall not make an enforcement order under section 65(1) if section 61(1)(a) (signing of agreements) was not complied with unless a document (whether or not in the prescribed form and complying with regulations under section 60(1)) itself containing all the prescribed terms of the agreement was signed by the debtor or hirer (whether or not in the prescribed manner).

 

 

and this was added to the CCA

 

 

140AUnfair relationships between creditors and debtors

 

(1)The court may make an order under section 140B in connection with a credit agreement if it determines that the relationship between the creditor and the debtor arising out of the agreement (or the agreement taken with any related agreement) is unfair to the debtor because of one or more of the following

 

 

my point is that government and courts don't like technical challenges of the agreements which can also be seen in the OFT guidance all to do with fairness

 

s127 CCA was all about tecnical breaches its gone now but why ?

 

there are good points of law to show that a dodgy DN is fatal to the creditors agreement but how the judge views it is a different matter.

 

HI WP3

Section 127(3-5) was repealed because it was said it infringed the human rights of the creditor in that it unfairly effected his rights for “peaceful enjoyment of his property”. It was decided that the removal of the courts powers to enforce as in 127(1) was not in then public interest to me it was a powerful ally to public interest in that it ensured basic requirements that creditors must follow but go figure.

As you say I think section 140 is the way to go now.

I have written a couple of Defences based on this and am waiting to see what happens. It is a particularly useful piece of legislation because it talks of things done or not done by the creditor.

This is a bit of a departure from conventional legislature I think because it is not talking about actions for breach, but actions that may not be a breech but never the less may be unfair. A step in the right direction lets hope

Peter

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Courtesy of Surfaceagent x20

 

post taken from

 

A Tale of a Dodgy DN

 

The contention advanced by ABC's lawyers was that if the DN was ineffective, the termination which ABC subsequently brought about in reliance upon that ineffective DN, was itself ineffective. In support, ABC said that since the law did not permit a creditor to terminate an agreement unless there had been serivce upon a debtor of an effective DN, by extension therefore, rather than having been terminated, the agreement endured.

 

The law in support of this proposition was Consumer Credit Act 1974 section 87(1)(a) which says:

 

(1) Service of a notice on the debtor or hirer in accordance with section 88 (a “default notice ”) is necessary before the creditor or owner can become entitled, by reason of any breach by the debtor or hirer of a regulated agreement (a) to terminate the agreement

 

ABC went on to say that owing to the agreement enduring, ABC were therefore at liberty to serve a second DN.

 

At first blush, that looks quite a convincing argument. The Act itself forbids the creditor the right to terminate save in certain circumstances. So if the required circumstances were not present, how could the law regard the agreement as having terminated?

 

[1] Termination of a Contract and General Principles

A good place to start would be to dispel the myth that the law will not tolerate contract breaking. On the contrary whilst not actively ncouraging it, the law will tolerate it. The courts will rarely impose upon one party an obligation to perform under a contract against its will, to do what it failed to do or redo what it tried and failed to do. Instead, what the law will do is on the one hand restrain the contract breaker from procuring the benefits it would have enjoyed had it fulfilled its contractual obligations and on the other, enable the injured party to recover damages flowing from the breach.

 

In Golden Strait Corporation v Nippon Yusen Kubishka Kaisha [2007], Lord Bingham said:

 

'The repudiation of a contract by one party ("the repudiator"), if accepted by the other ("the injured party"), brings the contract to an end and releases both parties from their primary obligations under the contract. The injured party is thereupon entitled to recover damages against the repudiator to compensate him for such financial loss as the repudiator's breach has caused him to suffer. This is elementary law.

 

The damages recoverable by the injured party are such sum as will put him in the same financial position as if the contract had been performed.'

 

What's more, the law will not merrily award whatever loss the injured party says he suffered. The court will require the injured party to prove his loss and further, will expect the injured party to take steps to mitigate the loss.

 

'An injured party such as the owners may not, generally speaking, recover damages against a repudiator such as the charterers for loss which he could reasonably have avoided by taking reasonable commercial steps to mitigate his loss.' [Lord Bingham in Golden Strait Corporation.]

 

Further still, in assessing damages the law will not even award what the parties may at formation of the agreement have agreed should be payable as liquidated damages in the event of breach. The court will not permit the recovery of liquidated damages unless the damages represent a fair pre-estimate of what loss might flow from the breach. If the liquidated damages are shown to be excessive and unrepresentative of the sactual loss suffered the law will readily declare the liquidated damages as a penalty and unenforceable.

 

In short, not only does the law tolerate contract breaking, but also, it will not tolerate the injured party taking advantage of the wrongdoer. The law does not pounce on the contract breaker to teach him a lesson. The court only awards the innocent party what damages truly flow from the breach. That admits of the possibility that a contract breaker can get away with it. If the injured party is unable to show resulting loss, the injured party may get nothing.

 

'One must look at the contract as a whole, and if it is clear that the innocent party has lost nothing, he should recover no more than nominal damages for the loss of his right to have the whole contract completed.' [Edmund Davies LJ in 'The Mihalis Angelos' (1971)]

 

[2] Termination in Non-Conformity with section 87.

The contention I advance is that an ineffective DN does not prohibit the creditor from terminating the agreement. Termination after service of an effective default notice is lawful termination, but as we have seen, a party may still terminate an agreement and be in the wrong for doing so. The law operates on a wrongful termination to offer to the injured party the choice of accepting the termination or to hold the contract breaker to his promise.

 

In the world of consumer credit, I contend a termination of the agreement by a creditor in terms whereby he announced he would no longer permit the debtor time to repay the credit, was a creditor in repudiatory breach of the agreement, unless in leading up to termination, the creditor complied with the requirements of the Act in circumstances where the debtor was in first breach of the agreement.

 

Further, and it is worth remembering, the Act is an Act for the purpose of consumer protection. The purpose of the Act is not to preserve the rights of creditors in contracts and to protect them from misadventure where for example, they terminated an agreement where it subsequently transpired the termination had not been in their interests. If that were so, the Act would have been an Act for the better protection of financiers.

 

In a proper case, the law will come to the aid of the vulnerable to protect them from the consequences of their contracts (for example the unsound in mind, children, those under duress or undue influence). To suggest financiers fell into that bracket and the Consumer Credit Act operated to protect them and not the consumer, was absurd. The civil law does not come to rescue the misadentures of the sain and the savvy.

 

The clue to the position of the creditor on termination is in the use of the word 'entitled' in section 87(1). 'Entitled' connotes a right or a benefit. The Act therefore confers rights, conditional upon the provisions of section 87(1) being fuilfilled. Fail to fulfill the condition and the entitlements do not become available.

 

In the case of a contract entered into by a person under duress and who then breaks the contract the law will come to that person's aid by recognising that person's plea that the contract was made under duress. If that person seeks a declaration of the court that the contract was made under duress the court wil readily declare the contract void.

 

If the Act had intended that a creditor's termination in circumstances where section 87(1) had not been fulfilled by the creditor and was to be of no effect, the Act would have declared that termination void. It doesn't. The termination is voidable at the option of the debtor.

 

[3] The Debtor's Point of View

Third, let us look at the position from the ordinary man as debtor's point of view in a consumer credit situation.

 

The DN is defective for failing to conform to the prescribed terms, or gives misleading information or at worse is plain nonsense so that the debtor does not know precisely what he has to do in order to comply with it and is consequently disadvantaged. Should the law disregard the fact that the creditor put the debtor at a disadvantage and thereby at risk the creditor might lawfully terminate the agreement?

 

'This statute was plainly enacted to protect consumers, most of whom are likely to be individuals. When contracting with a large financial organisation they are at a disadvantage. The contract is likely to be in standard form and relatively complex with a number of detailed provisions. If the hirer is said to have broken its terms, the hirer needs to know precisely what he or she is said to have done wrong and what he or she needs to do to put matters right.

The lender has the ability and the resources to give that information with precision. If he does not do so accurately then he cannot take what Mr Gruffyd conveniently referred to as "the next step". [per Kennedy LJ in Woodchester v Swayne [1998]]

 

Moving on, if the debtor receives a notice from the creditor in which the creditor expressly states the contract is terminated, what is the debtor supposed to think? Would the law regard him as likely to think the creditor had terminated the contract or would the law regard him as thinking it had not terminated because strictly speaking, the creditor had served a default notice which was not in accordance with prescribed terms?

 

Or where perhaps the creditor did not expresly terminate but sent the bully boys over to demand the keys to the car. What was the debtor to think then? Would the debtor think the creditor had terminated?

 

It seems to me on the basis of the passages below, the courts will be ready to hold a creditor to his words and actions.

 

"... a person who signs a document, and parts with it so that it may come into other hands, has a responsibility, that of the normal man of prudence, to take care what he signs, which if neglected, prevents him from denying his liability under the document according to its tenor".

[per Lord Wilberforce in Gallie v Lee (1971)]

 

'.. a man cannot escape from the consequences, as regards innocent third parties, of signing a document if, being a man of ordinary education and competence, he chooses to sign it without informing himself of its purport and effect..'

[per Scott LJ in Norwich & Peterborough Building Society v Steed (1992)]

 

In short, the creditor is bound by his deed. All that is required is for the debtor to accept the creditor's termination. He can write saying 'thank you I accept you termination' or he can conduct himself in a way in keeping with that termination. Not paying the instalments would be in keeping with an acceptance of the termination.

 

[4] The fiction of the Second DN and the Enduring Obligation

The service of any second default notice, at a time when the contract is terminated, owing to the wording of the DN in its prescribed form, would perpetuate the fiction that the contract endured. The same can be said owing to the provisions of section 89 of the Act.

 

The form of words in the DN incorporate text in order to meet the intention of section 89 of the Act which provides:

 

'If before the date specified for that purpose in the default notice the debtor or hirer takes the action specified under section 88(1)(b) or © the breach shall be treated as not having occurred.'

 

In other words, in serving the second DN, the creditor would be suggesting:

 

[a] an obligation had persisted post termination by which the debtor was bound to make instalment payments (ie post-termination 'arrears'), and that if payment of those 'arrears' was made, an obligation to make future instalment payments would endure.

 

The obligations at [a] are obligations enduring during the currency of the agreement. Besides maintaining the fiction of the enduring agremeent as I say, it seems to me any second DN would be bound to be defective for over-stating the sums due. The creditor can not state as an amount due for 'arrears' of instalments that which he said in consequence of his termination was no longer due and payable by instalments.

If the creditor sought to use a form of DN which made sense by getting round the fact the agreement had been terminated, the DN would not be in prescribed form.

 

The only way in which a second DN would be of value to the creditor would be where the contract had been re-instated. If the debtor has accepted the termination, re-instatement requires the consent of the debtor.

 

The net result of [1] to [4] is the agreement is terminated for all time. The creditor's remedy is now limited by section 87(1). All that is left for the creditor to recover is the sum truly in arrear at the date of the default notice.

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Peter

 

Isn't it the case that s89 requires the OC to offer the debtor an opportunity to remedy a breach "so that it shall be treated as not having occurred"? But if he does not offer that opportunity through failure to comply with s88, then takes the debtor to court (maybe even repossessing goods), the breach still exists but there is now no possibility of the debtor being able to remedy in line with s89. The opportunity has been permanently removed by the OC's unlawful (OK, let's say non-compliant) actions. There is no going back as the situation cannot be put back to how it was before the breach, unless the OC pays compensation and removes adverse data from the CRAs.

 

While s170 appears to remove the possibility of applying sanctions on the OC for its failure to comply with the Act, it remains grossly unfair to the debtor if he was unable to remedy a breach due to errors in a DN and then finds himself in court facing a judge that merely instructs the OC to issue a new DN, particularly where the OC has already terminated the agreement (perhaps not lawfully) and the debtor has engaged with the OC in court on the basis of the agreement being mutually ended.

 

If an agreement is ended, then monies due must be paid. However, where an agreement is ended by the OC on breach and without complying with s88 then, as s87(1)(b) tells us, the monies due do not include sums unpaid. The interpretation of this is that the only amounts due are the arrears, simply because it's impossible to see what other sums could be due (the OC has removed his entitlement to claim anything else, according to s87(1)).

 

All the creditors have to do is get this simple document correct and ensure compliance with s88. It is not difficult. However, given the fact that the banks really struggle with this with all their diligence, financial expertise and legal resources, I can't help wondering whether they prefer to avoid a debtor remedying a breach and instead seek the full amount in court, perhaps covered by a charging order. Or is that a bit too cynical?

 

LA

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All the creditors have to do is get this simple document correct and ensure compliance with s88. It is not difficult. However, given the fact that the banks really struggle with this with all their diligence, financial expertise and legal resources, I can't help wondering whether they prefer to avoid a debtor remedying a breach and instead seek the full amount in court, perhaps covered by a charging order. Or is that a bit too cynical?

 

LA

 

We could be forgiven for thinking this given the fact creditors have had many years to get this document right and for whatever reason appear incapable of producing a complicit notice.

 

As for your other comments on the creditor screwing the opportunity for the debtor to remedy and then shooting off to court under the pretence of being whiter than white I wholly agree. If they've messed the process up it should be the debtor who is protected first, given the fact that the creditor has already effectively witheld or even removed the consumer protection the law states the debtor should have.

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COPY OF AMEX V BRANDON FOR FREETHEMICE

 

SCAN FORUM Amex V BRANDON CASE[1].pdf

 

 

 

quote from Francis Bennion in regards of S127 OF THE CCA

 

Consumer Credit Act 1974 s 127(3)

As the draftsman of the Consumer Credit Act 1974 I would like to thank Dr Richard Lawson

 

for his interesting and well-argued article (30 August 2003) on

Wilson v First County Trust

Ltd

[2003] UKHL 40, [2003] 4 All ER 97.

Dr Lawson may be interested to know that I included the provision in question (section

127(3)) entirely on my own initiative. It seemed right to me that if the creditor company

couldn’t be bothered to ensure that all the prescribed particulars were accurately included in

the credit agreement it deserved to find it unenforceable, and that the court should not have

power to relieve it from this penalty. Nobody queried this, and it went through Parliament

without debate. I’m glad the House of Lords has now vindicated my reasoning and confirmed

that nobody’s human rights were infringed.

167 Justice of the Peace (2003) 773.

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Peter

 

Isn't it the case that s89 requires the OC to offer the debtor an opportunity to remedy a breach "so that it shall be treated as not having occurred"? But if he does not offer that opportunity through failure to comply with s88, then takes the debtor to court (maybe even repossessing goods), the breach still exists but there is now no possibility of the debtor being able to remedy in line with s89. The opportunity has been permanently removed by the OC's unlawful (OK, let's say non-compliant) actions. There is no going back as the situation cannot be put back to how it was before the breach, unless the OC pays compensation and removes adverse data from the CRAs.

 

While s170 appears to remove the possibility of applying sanctions on the OC for its failure to comply with the Act, it remains grossly unfair to the debtor if he was unable to remedy a breach due to errors in a DN and then finds himself in court facing a judge that merely instructs the OC to issue a new DN, particularly where the OC has already terminated the agreement (perhaps not lawfully) and the debtor has engaged with the OC in court on the basis of the agreement being mutually ended.

 

If an agreement is ended, then monies due must be paid. However, where an agreement is ended by the OC on breach and without complying with s88 then, as s87(1)(b) tells us, the monies due do not include sums unpaid. The interpretation of this is that the only amounts due are the arrears, simply because it's impossible to see what other sums could be due (the OC has removed his entitlement to claim anything else, according to s87(1)).

 

All the creditors have to do is get this simple document correct and ensure compliance with s88. It is not difficult. However, given the fact that the banks really struggle with this with all their diligence, financial expertise and legal resources, I can't help wondering whether they prefer to avoid a debtor remedying a breach and instead seek the full amount in court, perhaps covered by a charging order. Or is that a bit too cynical?

 

LA

 

 

 

HI La

I don’t think that the error on the DN permanently removes the opportunity for the debtor to remedy. If it is proved to be inaccurate it will give the debtor a further period to remedy which I think is the whole point of the exercise.

I think that the creditor would have had successfully ;litigated before repossessing any goods.

Why should the OC pay compensation? The breach is the debtors not his he is just trying to get his money back, really we must try looking at these things (and this is not a dig at you personally I am talking in general) from the point of view of the court, what damages can the debtor claim what prejudice, in reality he has the money he has failed to repay in the manor he agreed to.

The entrance of the debtors default on the CRA record is not dependant on the issuance of a default notice anyway and no CCJ would be placed till a month after the CCJ has been issued.

I agree it is unfair that a debtor is not able to remedy a default because the requirements stated are incorrect that is why it must be corrected and additional time given, it would be even more unfair to remove the creditors rights to his money because of an error in calculation(again I am sure the court would think so).

Section 87 1b simply says that the creditor cannot the enforce demand an accelerated payment of sums due under the agreement without a valid DN being issued, arrears can be demanded with or without any enforcement action.

I suppose that the banks may construct a situation where the debtor could not remedy if they wanted to force the closure of an account and acquire the rights to sue for recovery of liabilities, but that is why section 88 is there, if the DN is not correct then they cannot enforce that will be the situation until the court agrees that the DN they present is correct.

peter

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COPY OF AMEX V BRANDON FOR FREETHEMICE

 

SCAN FORUM Amex V BRANDON CASE[1].pdf

 

 

 

quote from Francis Bennion in regards of S127 OF THE CCA

 

Consumer Credit Act 1974 s 127(3)

As the draftsman of the Consumer Credit Act 1974 I would like to thank Dr Richard Lawson

 

for his interesting and well-argued article (30 August 2003) on

Wilson v First County Trust

 

Ltd

 

 

[2003] UKHL 40, [2003] 4 All ER 97.

 

Dr Lawson may be interested to know that I included the provision in question (section

 

127(3)) entirely on my own initiative. It seemed right to me that if the creditor company

couldn’t be bothered to ensure that all the prescribed particulars were accurately included in

the credit agreement it deserved to find it unenforceable, and that the court should not have

power to relieve it from this penalty. Nobody queried this, and it went through Parliament

without debate. I’m glad the House of Lords has now vindicated my reasoning and confirmed

that nobody’s human rights were infringed.

 

 

 

167

Justice of the Peace (2003) 773.

 

[/quote}

 

Yes it wa a sad los to the cca the issue of human rights was again raised(always suspected EU court intervention here) in the consultation document proceeding the production of the consumer protection legislation which was used to repeal the section of the CCA

 

Peter

Edited by Dodgeball

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