MSE News: Bank charges fighting on: a new legal argument

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  • lincroft1710
    lincroft1710 Posts: 17,543
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    Free banking usually means lending the bank money for virtually no interest and paying for extras you don't really need.
    If you are querying your Council Tax band would you please state whether you are in England, Scotland or Wales
  • david.l wrote: »
    Nice so martin can lead us all up the garden path again and we can all be dissapointed again and the banks will win again same old story the little people........

    I think Martin is doing an absolutely fantastic job in helping those who have, and are, being charged these astonomically unfair charges. :T I don't see anybody else out there helping, do you? If you think you could do a better job, you do it.

    A huge thank you to Martin for all his work on this past, present and future.

    To another blogger who says that we should budget our finances better-I have very high standards and morals and sometimes payments are taken out of accounts accidentally (maybe a standing order has been taken twice), which results in an account going overdrawn, and is therefore not the customer's fault. Loss of jobs, especially in the current climate, leading to loss of income is again out of the customer's control and as such, accounts are bound to go overdrawn. As another blogger wrote, it is then impossible to catch up as new charges are then put on top of other charges.

    I think it right that people should be able to reclaim these high charges as they are totally unfair and as Martin pointed out in his most recent information, the OFT must have a voice in this. Otherwise banks could charge whatever they like.
  • *MF* wrote: »
    I was pleased to see this joint action - good news.

    In that vein may I copy/paste a post I made on the Penalty Charges site today, which I hope may also be taken into account - specifically as it relates to Martin's comments near the end of his post.

    Post reads:
    For those who are trying to reclaim charges where an overdraft/borrowing was involved - on the face of it - perhaps read no further, but my hope is over time, there may be a chink in the armour over this issue of Basic Bank Accounts, which when opened up, may widen the net and bring everyone back on board - I don't know that, but that is what I hope may happen, we shall see.

    The lead in this issue from an "official/regulatory" position has been the OFT, and my direction is to focus away from them to develop what I am looking at - there will be plenty on this forum and other forums who will be following up what response comes from the OFT based on the hints the Supreme Court gave them.

    That is why I mentioned the FSA, (and the FOS) - and the essential difference between a regulatory regime for "Deposits", and that for "Credit".

    So where sit the FSA just now - this from their website:

    FSA begins banking regulation

    We will begin regulating banks' and building societies' day-to-day contact with their customers from 1 November 2009. This new framework will deliver wide-ranging benefits for consumers.

    That is my starting point, their involvement exists, they cannot escape it - but the dividing line as we stand today, takes us back to the dividing line of "Deposits" and "Credit/Borrowing".

    It is well established that the FSA have promoted intensively their "Treating Customers Fairly" initiative, and many of the regulatory actions they have taken against financial firms and intermediaries have their genesis in that initiative - so the FSA lay great importance on "fairness".

    Beyond the FSA lie the FOS - so a consumer in the absence of that "fairness", can raise a complaintand go to the Financial Ombudsman Service, whose assessments are also rooted in "fairness and reasonableness" (or so they say) - and as importantly they have been in print and in action establishing that they are NOT bound by the law as laid down by courts.

    Where am I going with this?

    Well, perhaps evidence first, staring with mine, and perhaps other posters may in time add to this - part of my reason for coming on board:

    One of my Bank Accounts is a Basic Bank Account. On the 20th of April 2008, it had a credit balance (a deposit) of £37.99.

    On the 21st of April, a DD was payable to British Gas of £38.00.

    My balance was insufficient, so the DD was not paid.

    However, the Bank did immediately levy a charge of £38.00.

    Now apart from the coincidence over the amounts, was I granted an overdraft, was I borrowing that money - nope, because a Basic bank Account has explicit, clear, and intelligible criteria from the outset - it excludes overdrafts and any form of credit/borrowing.

    So to whom should I refer the matter, which Regulator, the OFT, the FSA, the FOS?

    Let's say no more than it is a fair question, and not one I can find has been asked before, and that is why I agreed initially with the comment that we need to step back and take stock.

    Now maybe, this forum and others can lead me to evidence in greater abundance than just mine - in this area of Basic Bank Accounts - more evidence would help.

    But even in the absence of such - I hope to take this question further, and as I said I have other aspects beyond this which I will touch upon later - but for now, this one area seems to me to be the one to concentrate on.

    May I ask therefore, apart from any comments, whether there are other posters on this forum, who have a Basic Bank Account, with circumstances similar to the one I had?



    I used to have a basic bank account also and when I knew I was going to go overdrawn, but not able to stop the payment, being too late in the day, the bank refused an overdraft facility. I have banked at this particular bank for over 26 years and in all that time they have never granted me an overdraft facility, despite have a well paid teaching job at the time. Now I am out of work and they still won't grant me an overdraft facility, despite desperately needing it now. I'd like to know how rich or poor I have to be to get one. It seems to me they just pick and choose and if for some reason they don't like your face, forget it. Despite this, with every letter I receive from them kindly informing me of my extortionate charges, they include a letter which suggests I contact them regarding an overdraft facility. I give up.
  • vaporate
    vaporate Posts: 1,955 Forumite
    Free banking usually means lending the bank money for virtually no interest and paying for extras you don't really need.

    I agree with this.

    The bank has your money, yet you gain little interest, even in a savings account. Yet get charged through the nose the moment you are over an authorised overdraft, even by 1p.

    It's not a case of being careful with your money, specially if you are unemployed with a mortgage. Thankfully I'm in neither negative position.
    Hi, we’ve had to remove your signature. If you’re not sure why please read the forum rules or email the forum team if you’re still unsure - MSE ForumTeam
  • jdx
    jdx Posts: 226 Forumite
    jju5t wrote: »
    I expect nothing back from the banks regarding charges.

    i will take them to court just to use up their (high cost lawers)time and cost them more than my charges are worth in defence fees.

    and then i will complain to the ombersman just to cost them another £500 for the investigation.

    PEACE
    :D That's a start.
  • In a lot of cases I would imagine it's just the snowball effect of tight budget being eaten by charges, it's definately my case. When i've forseen that I may go overdrawn, I've requested an overdraft facility for just one month.. and been told not on my account because it's basic, so when I've asked to upgrade to an account that has the facility, I'm told no.

    But why should a bank give me a facility that covers my costs occasionally when they can make £35 every other month or so off my back.

    I've requested details of charges I've occured so wait on baited breath to see the route that we will take now.


    I used to have a basic bank account also and when I knew I was going to go overdrawn, but not able to stop the payment, being too late in the day, the bank refused an overdraft facility. I have banked at this particular bank for over 26 years and in all that time they have never granted me an overdraft facility, despite have a well paid teaching job at the time. Now I am out of work and they still won't grant me an overdraft facility, despite desperately needing it now. I'd like to know how rich or poor I have to be to get one. It seems to me they just pick and choose and if for some reason they don't like your face, forget it. Despite this, with every letter I receive from them kindly informing me of my extortionate charges, they include a letter which suggests I contact them regarding an overdraft facility. I give up.
  • hope this helps..........


    FSA's interpretation of the Unfair Terms in Consumer Contracts Regulations 1999



    Related information

    Speech by Katherine Webster, Manager of the Unfair Contract Terms Team, FSA
    CML's 7th annual legal issues for mortgage lenders conference
    13 January 2009

    Treating Customers Fairly

    As you will be aware, the FSA continues to move towards a more principles-based approach to regulation, where we rely increasingly, insofar as possible, on principles and outcome-focussed rules, rather than detailed rules prescribing how those outcomes must be achieved. Principles-based regulation is even more important and relevant in turbulent times such as these, when detailed rules would not be able to keep pace with an ever-changing financial environment.
    Treating Customers Fairly is a core part of the move to more principles-based regulation, and you will all be familiar with it. We expect all firms to be able to demonstrate they are treating their customers fairly and it was very heartening that another finding from the Practitioner Panel’s survey was that the firms surveyed had an overwhelmingly positive attitude to the concept of treating customers fairly.
    Contrary to some articles you may have read towards the end of last year, TCF - which has now been included within our core supervisory work - remains a very high priority within our Retail Strategy. And fair contract terms are a key and very visible factor in firms treating their customers fairly. Or, conversely, unfair contract terms - which we continue to see in contracts across the range of financial services products, including mortgages - are a strong indicator of firms' failure to embed achievement of TCF outcomes into their business operations.
    We did some work last year to assess firms' awareness of and compliance with the Regulations, and the extent to which the outcome of fair terms in consumer contracts was being achieved. We published a report in June 2008 setting out our findings and giving examples of good and bad practice among firms. Mortgage contracts were among the contracts that we reviewed and, of the 20 contracts that we reviewed, 15 had at least one variation term that we considered to be unfair. I am sure that some of you here will have dealt with our correspondence on this during our follow-up work from the reviews.
    We want to ensure that firms recognise fair contract terms as an important part of TCF and all of you here have a role to play in this. I will make some practical suggestions around this later, and there is a great deal of material on our Unfair Contract Terms webpages that you can review at your leisure, and that we hope will be helpful to you.
    The Regulations

    Let me move on now to talk about the Regulations themselves. The Regulations apply across diverse business areas, of which financial services is but one. They are written in general terms and their interpretation is a matter for the Courts. To assist firms in interpreting and applying the Regulations, we published a Statement of Good Practice on the 'Fairness of Terms in Consumer Contracts' in May 2005. It sets out our interpretation of the Regulations in relation to contracts for products and services that are within the FSA's regulatory scope, with particular reference to variation terms, about which we receive a large number of complaints.
    The Regulations implement an EC Directive - Council Directive 93/13/EEC of 5 April 1993 - and they came into force in July 1995. We gained our powers under them in 2001 although we only began regulating mortgage contracts in 2004. However, under the Regulations - and this might come as a bit of a shock to some of you (although I hope not!) - we can consider the fairness of terms in mortgage contracts from July 1995 onwards. That means that we can look at mortgage contracts that pre-date FSA regulation and that pre-date FSMA. And we do receive complaints about such contracts.
    There are some limits to the mortgage contracts we can look at under the Regulations - for example, we look only at first charge mortgages. Second charge and buy-to-let mortgage contracts fall to the Office of Fair Trading (OFT), the principal enforcer of the Regulations, for consideration. We have an agreement - a Concordat - with the OFT setting out our respective responsibilities for financial services contracts under the Regulations. The Concordat is available on our website but, broadly speaking, we deal with contracts from authorised firms carrying out regulated activities and the OFT deals with all other standard-form financial services contracts.
    We interpret the Regulations in accordance with the objectives of the Directive and the recitals to the Directive provide some insight into these. A reference in the recitals underlines the importance of protecting consumers from unfair contract terms and from 'one-sided standard contracts and the unfair exclusion of essential rights in contracts.' It is apparent from the recitals that we should also have regard to the bargaining strengths of the parties, any inducement which would cause the consumer to agree to a particular term and whether the firm is dealing fairly with the consumer, taking the consumer's legitimate interests into account.
    The test to determine whether a contract term is fair or not is set out in Regulation 5(1) "a contractual term which has not been individually negotiated shall be regarded as unfair if, contrary to the requirement of good faith, it causes a significant imbalance in the parties' rights and obligations arising under the contract, to the detriment of the consumer."
    Regulation 5 is always our starting point and when we apply the fairness test, we consider the overall fairness of the particular term in the context of the contract as a whole. For instance, an unfair term in a mortgage contract might cause greater detriment to the consumer if he is unable to avoid the term by withdrawing from the contract because of various applicable fees and, possibly, an early redemption charge. By contrast, a similar term in, for example, a contract for an instant access savings account might cause little or no detriment as the consumer can walk away from it more easily.
    Fairness is a wide concept and, like principles-based regulation, is not a matter of rigid requirements. So – and despite the fact that the title of this speech refers to the legal interpretation of the Regulations – it is sometimes not helpful to get caught up in a detailed legal analysis of what is, or is not, 'fair'. It may sound strange for me, as a lawyer, to say that, but we have found that sometimes it is helpful, when considering whether a term gives rise to a 'significant imbalance in the parties' rights and obligations', to take a step back and consider whether each party to the contract would have thought the term fair from the other’s perspective at the time the contract was formed between them. We find that this helps us to take a balanced approach to the issue of fairness and you might find it equally helpful if you were to adopt this, or a similar method, when drawing up, and advising on, mortgage terms.
    Regulation 5 refers to the concept of good faith and, again, it can be helpful to take a rounded view of what this may mean. Good faith was dealt with in the judgment of the House of Lords in the case Director General of Fair Trading v First National Bank Plc [2001] UKHL 52 (slide b) with Lord Bingham saying that it was "not an artificial or technical concept". His Lordship explained that the requirement of good faith is one of "fair and open dealing" and that openness requires terms to be expressed "fully, clearly and legibly, containing no concealed pitfalls or traps".
    (Slide c) Lord Bingham went on to say that fair dealing requires that firms should not, deliberately or unconsciously, take advantage of consumers, whether because of their lack of experience, unfamiliarity with the subject matter of the contract, weak bargaining position or a number of other factors.
    We think that this description of fair dealing ties in very nicely with the whole concept of treating customers fairly (slide d) and I hope that this slide demonstrates the link between Regulation 5 and Principle 6 of our Principles for Businesses.
    A further aspect of Regulation 5 is that the significant imbalance must be to the detriment of the consumer. Our view is that this detriment may be actual detriment or potential detriment - so, in other words, even if an unfair term is not being applied unfairly in practice we still consider if there is the potential for consumer detriment in the event that the term was to be applied unfairly. And, as a risk-based regulator, we form a view as to the extent of the actual or potential detriment and its impact on consumers.
    I should also mention Schedule 2 to the Regulations which sets out an indicative, non-exhaustive list of terms which may be regarded as unfair. I should like to stress that Schedule 2 is indicative only and, whilst it can provide a useful basis upon which to consider further whether a contract term is unfair, the test of fairness is contained in Regulation 5. Also, the fact that a particular term in a contract does not offend or is not included in those listed in Schedule 2 may not, of itself, remove the risk of unfairness.
    Turning now to Regulation 7(1) It states that a firm "shall ensure that any written term of a contract is expressed in plain, intelligible language."
    It might serve as a useful reminder that if a term is not drafted in plain, intelligible language and there is doubt as to its meaning, then under Regulation 7(2) it is to be interpreted in the way most favourable to the consumer. It is, therefore, undoubtedly in firms’ interests to ensure that their contract terms are clear and unambiguous.
    We are still surprised by how many consumer contracts are drafted in legal jargon. Last year we published a statement advising firms that the use of language such as 'consequential loss' in their consumer contracts is not, in our view, plain and intelligible and that terms using this kind of language may be unfair. This message was reinforced in an undertaking we published from a firm agreeing to stop using the phrase 'consequential loss' in its contracts. And, towards the end of last year we also published an undertaking from a firm which agreed not to use the word 'indemnify' in its consumer contract as, among other concerns, we did not think that the average consumer would understand the implications of a term whereby he agrees to 'indemnify' a firm. How many of you are confident that your firm's consumer contracts are free of legal jargon and are in plain, intelligible language? It is worth bearing in mind that the whole purpose of Regulation 7 and the obligation on firms to use plain language is to ensure that consumers – and not just lawyers – can understand the contract and can make an informed choice as to whether to become a party to it in the first place.
    Before I move on from Regulation 7, (slide f) I hope that this slide will demonstrate its close relationship with Principle 7 of our Principles for Businesses.
    Both this slide and the previous one illustrating the relationship between Regulation 5 and Principle 6 demonstrate very tangibly how firms should consider their fairness obligations in the round. There is a clear overlap between the Regulations and our Principles for Businesses. The Regulations apply to terms in a standard-form contract but the Principles apply to the way that those terms are applied in practice, not just the way they are drafted. So a firm must not use an unfair term (or a fair term) unfairly in practice. Also the Principles apply to the ‘core terms’ of a contract. These are the terms which set the price or describe the main subject matter of the contract and they are generally not reviewable for fairness under the Regulations, provided they are written in plain, intelligible language.
    Our practice under the Regulations

    Concerns about potentially unfair contract terms are referred to us from many different sources: individual consumers; consumer groups; the OFT; the Financial Ombudsman Service; Citizens Advice Bureaux; Trading Standards; and from our own FSA supervisors.
    So, what happens when we receive a complaint under the Regulations? There is guidance on how we use our powers under the Regulations in a section of the FSA Handbook – the Unfair Contract Terms Regulatory Guide - that we refer to as 'UNFCOG' - and I will give you a brief overview now.
    We can form a view as to whether we think a contract term is potentially unfair, but only a court can decide whether it is actually unfair. We have a statutory duty to consider every complaint that we receive, although we will not necessarily take action in every case. As a risk-based and proportionate regulator, we carry out a risk assessment to assess the level of actual or potential detriment to consumers posed by an unfair contract term. We do this to ensure that our resources are directed where they are most needed and where they will have most impact in protecting consumers.
    When we do decide to take a complaint forward, we seek the firm’s co-operation. We will ask the firm to agree to delete the term, or to amend it so that it is fair. We also ask the firm to undertake to treat existing customers fairly by treating them as if the new, fairly-drafted term was in their contracts. We generally expect the firm to notify consumers of the change and we will publish the undertaking given to us by the firm on both the OFT and our own website, including details of the contract and the amendments. Publication is a requirement under the Regulations.
    Yesterday we published our latest undertaking, which is from a mortgage lender. In that case the contract reserved certain powers to the lender - to withhold the mortgage, forbid any further drawdowns or demand immediate repayment of the mortgage, each in certain specified circumstances. Whilst we have no objection, per se, to lenders reserving such powers to themselves in a mortgage contract, we considered that, in this case, the ability to exercise some of the powers in some of the circumstances gave rise to a significant imbalance in the firm's power over its borrowers and was therefore unfair. For example, the lender’s power to demand immediate repayment of the mortgage could be exercised where the borrower exceeded his overdraft even by a relatively minor amount. Pursuant to the undertaking it has given us, the lender has redrafted the contract so that it may only exercise these powers where there are commensurately serious grounds for doing so.
    If we receive a number of complaints about the same issue, this may be an indication that there is a wider industry problem with that particular contract term and so we may undertake a wider review of contracts. You will recall that this is what we did when we became aware of a problem with variation terms in mortgage contracts relating to mortgage exit administration fees. The CML played an important role in highlighting our concerns with those particular terms.
    If we conclude that a term in a mortgage contract is not unfair under the Regulations, that is not necessarily the end of the matter. We are mindful of firms' obligations under MCOB, as well as TCF and our Principles for Businesses – that is why I began this morning by referring to the 'regulatory context' in which we operate. So, if we believe that some aspects of a firm’s practice are unfair, even though the term complained of is not, the FSA will follow this up.
    Myths

    There are a number of myths which have grown up around unfair contract terms and we know this because we have regular discussions with firms about unfair terms. I think that this morning presents a very good opportunity to dispel some of these myths.
    Firms say to us that, 'yes, our term might be unfair on the face of it, but it is not applied unfairly in practice and that is what matters'. We do not agree. We are always very glad to hear that firms are not trying to enforce unfair terms against consumers – but the simple fact of the matter is that unfair terms are not legally binding on consumers anyway. Regulation 8(1) makes that quite clear. And how is the consumer, who has only the term set out in black and white in the contract in front of him, supposed to know how the firm will choose to apply the term in practice? Is that ‘open and fair dealing'? We do not think so. If a contract term is drafted in a way that is unfair and does not reflect a firm’s practice, why can it not be redrafted so that it is fair and it does reflect the firm’s practice and intentions? That would be open and fair dealing with consumers.
    We publish a lot of material to assist firms in meeting their requirements under the Regulations. Another myth that we have come across is that firms need only pay heed to those publications that relate to their particular business area. So, for example, you might think that you need only keep up-to-date with undertakings relating to mortgages. That is not the case. The undertakings and other materials that we publish provide a good indication as to our views on the fairness of particular terms, and also give an insight into our interpretation of the Regulations and what we consider to be fair or unfair generally – and what we believe a court might consider fair or unfair. Such indications may be applicable across a range of contracts and business areas. Not all will have direct application or relevance to mortgage contracts, but many will. For example, I referred earlier to a statement and an undertaking we published last year advising firms that the use of legalistic language such as 'consequential loss' is not, in our view, plain and intelligible. Whilst this terminology is more likely to be found in an insurance contract, publication of this statement and undertaking should have alerted firms generally to the fact that their standard-form consumer contracts should not contain technical or legal terminology. The messages contained within the statement and the undertaking are therefore equally as relevant to those of you in this audience as it would be to a gathering of lawyers from firms providing general insurance.
    Similarly, the undertakings and guidance materials published by the OFT will not necessarily relate directly to mortgage contracts, but the indications they contain as to what may or may not be considered fair may be a very useful source of material for you in advising your firms about their mortgage contracts.
    A third myth is that when we consider a particular contract term to be unfair and ask for only that term to be amended or deleted, the rest of the contract must be fair. That is not necessarily the case and is a dangerous assumption. When we receive a complaint about a particular term, we consider only the fairness of that term – albeit that we consider it in the context of the contract as a whole. We are not a contract approval authority and we do not have the resources to consider every term in every contract referred to us. Even where a contract term is amended as a result of our intervention, it may still be subject to further scrutiny if we receive further complaints or other intelligence about it. As I have already indicated, we have a statutory duty to consider every complaint we receive, and this includes those that relate to terms that have already been amended.
    The risks posed by unfair terms

    I hope that I have successfully communicated to you how important fair contract terms are. However, if I have not, I would like to tell you about the risks posed for firms that have contracts with unfair terms.
    Unfair terms pose legal risks to firms. They are, as I have already said, unenforceable against consumers.
    And, it may not be prudent for a firm to rely on revenue sourced from such a term. For example, where a firm seeks to rely on an unfair term relating to the variation of charges to increase the amount it requires consumers to pay, and that term is challenged and deemed to be unenforceable, how is the loss of that anticipated revenue going to affect the firm financially? Another very recent example relates to certain terms we have seen in mortgage contracts enabling firms to impose a floor, or to determine the interest rate payable by the consumer once a certain 'trigger' in the benchmark rate is reached. Generally, we are not concerned with the fairness of an interest rate floor per se, but we do urge firms to ensure that they are drafted in a way which is balanced and fair. Furthermore – and here again the wider regulatory context I have spoken of several times this morning comes into play – we require firms to ensure that the consumer is made aware of the existence of a floor, trigger or similar feature in an appropriate manner and at both the pre-application and offer stages, in accordance with our Mortgage Conduct of Business rules.
    There is also operational risk to firms in having unfair terms. Time –your time – will have to be spent drafting or approving new, fair contracts and issuing them to consumers.
    And, finally, let us not forget about the risks to reputation, perhaps especially significant in the current climate. Will consumers really want to do business with firms who, on the face of it, do not meet their legal and regulatory obligations for fair contract terms and fair treatment of their customers?
    What we expect from you and what you can do to assist your firms
    We think that you, as legal advisers to your firms, are ideally placed to assist senior management in discharging firms' responsibilities under the Regulations. There are a variety of ways in which you can do this:
  • *MF*
    *MF* Posts: 3,113
    First Post First Anniversary Combo Breaker
    Forumite
    edited 27 November 2009 at 8:44PM
    ^ Thanks indeed finlander!

    Per my earlier post above - it is important that I stress I am still concentrating my thoughts on Basic Bank Accounts, and find this interesting:

    Extracts from the FSA web-site (red items - down to me):

    What might be an unfair term?


    An unfair term may, for example:
    • allow the firm to change the terms of the contract, without telling you why or without giving you notice as soon as possible so you can leave the contract immediately;
    • bind you to hidden terms;
    • exclude or limit your legal rights unfairly; or
    • charge you a disproportionately large sum if you don’t fulfil any of your obligations under the contract.
    These are just a few examples of terms that could be unfair. However, a term is not necessarily unfair just because it looks like one of these. It depends on the precise details of the contract as a whole. You can see some terms we’ve found to be unfair at Unfair contracts.



    What can we do?


    We can investigate complaints about terms in the following types of financial services contracts:
    • mortgages and the selling of mortgages;
    • insurance and the selling of insurance;
    • bank, building society and credit union savings accounts;
    • pensions;
    • investments; or
    • long-term savings.
    From here:

    http://www.moneymadeclear.fsa.gov.uk/about_the_fsa/unfair_contracts/unfair_contract_terms.html
    If many little people, in many little places, do many little things,
    they can change the face of the world.

    - African proverb -
  • As an aside, has anyone ever noticed that all QCs are always described as "top QC Fred Bloggs..." Never "pretty average QC" or "mediocre QC"
    ...much enquiry having been made concerning a gentleman, who had quitted a company where Johnson was, and no information being obtained; at last Johnson observed, that 'he did not care to speak ill of any man behind his back, but he believed the gentleman was an attorney'.
  • As an aside, has anyone ever noticed that all QCs are always described as "top QC Fred Bloggs..." Never "pretty average QC" or "mediocre QC"

    Well, would you read the article that said mediocre QC Fred Bloggs suggested pulling down your pants in front of the queen was the right thing to do.....probably not.

    I think in legal terms it is the £££ per hour that differentiates Good, very good and simply fantastic ;)
    I have not worked for NatWest Bank since February 2009

    This username is no longer active.
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