Money Advice Update – August 2018

Money Advice Update – August 2018

John McGleish v Graham Cameron Tough and Maureen Leslie

This case, decided by the Sheriff Appeals Court considered an obscure area of bankruptcy law, which has not seen much discussion, nor had much judicial consideration since its introduction in the Bankruptcy (Scotland) Act 1913.

The provision, now contained in section 78 (9) and (10) of the Bankruptcy (Scotland) Act 2016, (previously section 31(5) of the Bankruptcy (Scotland) Act 1985), relates to the non-vested contingent interests of the debtor.

The facts of the case were Mr McGleish and his wife took out a life insurance policy with critical illness insurance in 2001. They were then sequestrated in 2008 and received an automatic discharge in 2009. In 2010, Mrs McGleish passed away and her trustee took the proceeds from her life insurance policy.

The reason for this was the deceased’s interest in her life insurance policy was believed to vest with the trustee and was, therefore, a realisable asset that the trustee could use for the benefits of her creditors.

However, the argument put forward for Mr McGleish and which the Sheriff Appeal Court upheld, was that the life insurance policy constituted a non-vested contingent interest and, therefore on the discharge of Mrs McGleish in 2009, because of changes introduced by the Bankruptcy and Diligence Etc. (Scotland) Act 2008 (2008 Act), reinvested in her post-insolvent estate.

The argument being that the interest in a life insurance policy, which is only payable on death, only vests in the debtor on the purification of the contingency, which is death. The interest, therefore, is a non-vest contingent interest.

It is known that what constituted a non-vested contingent interest was never clear and even when the 2008 Act was passing through the Scottish Parliament one Scottish Government solicitor described it as unfathomable.

However, the argument has previously been made to the Accountant in Bankruptcy (AIB) that life insurance policies were non-vested contingent interests.

In one case that this author was involved in, they even gave a direction ruling against such an interpretation. It is, therefore, known that policies have been taken by the AIB, where it now is clear they had no legal basis for doing so.

Non-vested contingent interests now re-invest in debtors, not on their discharge, but if sequestrated after the 1st April 2015, on the expiry of 4 years from the date of their sequestration.

The Debt Arrangement Scheme (Scotland) (Amendment) Regulations 2018

The Scottish Government have put before the Scottish Parliament the latest changes being proposed for the Debt Arrangement Scheme.

The Regulations, which will be considered by the Economy, Jobs and Fair Work Committee, are aimed at increasing access to the Scheme, which in recent years has seen a substantial drop in the number of consumers applying to it.

They are also designed to reduce the likelihood of Debt Payment Programmes (DPPs) under the Scheme being revoked, after it was revealed that 2016-17 was the first year, in the history of the Scheme, which commenced in 2004, where more DPPs were approved than revoked.

The primary changes that are being introduced, are first to remove the requirement that debtors need to include all their debts in proposals to creditors.

This requirement was first introduced in 2013 and meant that even mortgage and rent arrears had to be included, despite the fact that although DPPs are diligence stoppers, they do not step creditors or landlords raising actions for repossession or eviction.

Although, the proposed changes do not exclude the possibility such debts can still be included, they allow, where they are omitted, for money advisers working with debtors to work with the debtor’s secured creditors and landlords to avoid any action for repossession or eviction. It may be that such changes will allow such creditors to obtain a priority status again and allow these debts to be cleared off quicker.

The other fundamental change that will be introduced will allow debtors to not have to offer their full disposable income to creditors when proposing a Debt Payment Programme. This change, it is believed, will be more controversial and some creditors may be inclined to object where they are offered only part of the debtor’s disposable income.

However, with the average length of a DPP now being over 7 years, the concern is that debtors are being expected to live on quite austere budgets, which although sustainable over the 4 year payment period in sequestration and protected trust deeds, is not suitable for longer term repayment plans. The counter argument to creditors who object to such proposals being that they will recover more through the Debt Arrangement Scheme, not only over its lifetime, but even in the first four years.

If passed the Debt Arrangement Scheme (Scotland) Regulations 2018 will commence on the 29th October 2018.

Common Financial Tool (Scotland) Regulations 2018

At the same time the new Debt Arrangement Scheme Regulations were laid in front of parliament, the Common Financial Tool (Scotland) Regulations were also laid.

The Common Financial Tool (CFT), first introduced on the 1st April 2015, is the income and expenditure tool that is used to determine how much debtors can pay towards their bankruptcy or protected trust deed. The preferred CFT is currently the Common Financial Statement ( CFS) that is produced by the Money Advice Trust, but the new regulations proposed this should become the Standard Financial Statement (SFS), which is owned by the Money Advice Service.

The decision by the Accountant in Bankruptcy to recommend the adoption of the SFS as the new CFT has proven controversial, as it is believed in some circumstances it may result in debtors paying more than they were required to pay under the CFS, or being required to pay a contribution where they were not required to under the CFS.

This is important, as one of the requirements for a Minimum Asset Bankruptcy, where the application fee is £90, is that the debtor cannot afford to make a contribution towards their bankruptcy. Where they can make a contribution, they must not only pay that contribution for 4 years, but also must use the Full Administration Bankruptcy procedure which has an application fee of £200.

Both tools are also controversial because of the way they are designed and formulated. Both break down a debtor’s expenditure into categories, such as essential expenditure and household expenditure. These categories, except the essential expenditure category, then have trigger figure assigned to them, based on the household composition of the debtor, which act as a rebuttable presumption that any expenditure over that amount is unreasonable.

The trigger figures for both Schemes are arrived at by looking at the average expenditure of the lowest 20% group contained in the Living Costs and Food Survey produced by the Office of National Statistics.

The argument why this is an inappropriate methodology to use to calculate trigger figures is that such a group are already living in poverty, with many dependent on means tested benefits to survive. Also the survey only shows what people are able to spend, rather than what they require to spend to afford a reasonable standard of living. The flaws in the methodology were recently exposed when the update trigger figures for the Common Financial Statement actually had some of the trigger figures being reduced at a time when it was clear living costs are increasing.

The regulations, however, have been withdrawn, as due to a timing error, they would not have been passed until after the summer recess and would have commenced on the 29th October 2018, leaving insufficient time for money advice agencies to adapt case management software systems and for training to be provided.

The Scottish Government have indicated they will resubmit the regulations after the summer recess with a view to commence them in April 2019.

Money Advice Update – April 2009

Money Advice Update – April 2009

First published in the April 2009 edition of SCOLAG.

The first quarter of this year, unsurprisingly, has been one of rumours and speculation for the money advice community.  Advisers have been eager to discover what changes the Scottish Government would introduce to help normal, hard working families with the credit crunch. 

As the picture begins to crystallise, the wait is almost over.

DEBT ACTION FORUM

Fergus Ewing, the Minister for Community Safety, began by announcing on the 13th of January that he was launching a Debt Action Forum to ensure the Scottish Government was doing everything within its powers to assist debtor’s struggling with the current financial downturn. There would also be a special housing sub-group to look at the issue of what else the Government could do to prevent repossessions[1].

The Forum has now met four times and is due to submit its proposals by the end of May.

Already a number of proposals have been considered, such as voluntary protocols for collections agencies and contribution only trust deeds, which may exempt debtors’ homes, with the consent of creditors.

It has also been mooted the possibility of the AIB expanding its functions, to provide an online and telephone advice service[2]. This is the reoccurrence of an earlier debate that took place during the passing of Bankruptcy (Scotland) Act 1993.

Then it was dismissed as a possible conflict of interest and it is believed many of the arguments which were valid then, are still valid today. It has also been expressed that it will be a duplication of existing services, provided by the National Debtline. A service already funded by the Scottish Government.

DEBT ARRANGEMENT SCHEME

The Accountant in Bankruptcy has also announced she will be taking over the full administration of the Debt Arrangement Scheme, including the management of cases. It is hoped this will free up the time of local Money Advisers, in order that they can devote more time to providing face to face advice to clients.

Other proposed changes to the Debt Arrangement Scheme, will be:[3]

  • Debtors being able to apply directly to the Scheme, through an online application process or an Approved Adviser
  • There no longer being a requirement for debtors to have two or more debts, allowing debtors with single debts to apply
  • The abolition of deemed consent, which allowed a creditor’s consent to be implied, when they fail to respond to notifications
  • The extending of the DAS Administrator’s power to apply a fair and reasonable test, in deciding if a payment programme should be approved, unless creditors’ with more than 50% of the total debt, actively express their consent.
  • A requirement for debtors to be able to make a minimum payment of £100 per month, or 1% of their total debt, whatever is the highest, towards their programmes and complete it within 10 years at most

It is hoped these changes will provide one point of contact for all debtors and creditors and increase the legitimacy of the scheme, as a result of it being operated by a Scottish Government agency.

It is also intended, despite the expansion of the gateway into the Scheme, debtors will still be encouraged to seek the advice of money advisers first. Although this will remove the requirement for Approved Money Advisers, it is likely money advice services will continue to play a pivotal role in the Scheme, particularly if the low Income, Low Asset Bankruptcies are an indication of the needs of debtors, where up to 90% of all applications are being made via advisers.

The other change, that debtors with single debts will be able to apply, will address some of the concerns that too much court time is taken up with Time to Pay Directions and Orders under the Debtors (Scotland) Act 1987. However, it is unlikely this provision will not be as successful as it could be, if debtors with single debts are still required to make a minimum payment of £100 per month. In the case of multiple debts, the minimum payment criteria is unlikely to be too great an obstacle, as the average payment in a Debt Payment Programme is already well in excess of this.

The removal of deemed consent will address the AIB’s concerns with lengthy repayment programmes being approved as a result of creditor’s failing to respond (over 90% of DPPs are currently approved as a result of deemed consent)[4].

It is, however, unlikely to do anything to address the lack of participation by creditors, and is likely only to encourage their continued lack of involvement.

BANKRUPTCY AND DILIGENCE ETC (SCOTLAND) ACT 2007

The new statutory Action of Arrestment and Furthcoming appear set to come in to force from April 22nd 2009, as are the further changes to inhibitions (see SCOLAG 375).

Earning Arrestments

From the 6th of April, new Earning Arrestment Schedules will be implemented.

The minimum amounts protected from arrestment, will change  to:

  • Daily: exceeding £13.50
  • Weekly: exceeding £94
  • Monthly: exceeding  £410

There will now be a clear flat rate of arrestment of 20% from any amount above those figures, up to:

  • Daily:  £88
  • Weekly: £617
  • Monthly: £2,680

After which 50% of the earnings will be deducted.

Land Attachments and Adjudication for Debt

Alex Salmond’s announcement in August 2007, at the Citizen Advice Scotland conference, that he will not allow the new diligence of Land Attachment to be used against the principal home, continues to delay its implementation.

Gillian Thompson, the AIB, has also expressed concerns that there may need to be further changes to the BAD Act 2007, as the legislation may no longer hang together.  There is now likely to be a three month consultation on the future implementation of the changes in diligence, beginning in March 2009[5].

What is of more concern, however, is the continued delay in abolishing Adjudication of Debt, which should have been abolished with the implementation of Land Attachments.

The delay allows creditors to increasingly use this diligence, interest in which has been revived, with the number of adjudications being registered in 2007/2008 being in their hundreds, whereas a few years ago, the number registered could have been counted on one hand. 

This situation is clearly contrary to the policy of the current Government, that is unsecured creditors should not be able to attach the principal home of debtors.

Money and Residual Attachments

It is now intended the new diligence of Money Attachments, will be implemented in July 2009. This will allow Sheriff Officers to attach the money of debtors, when it is in their possession, but not when it is kept in a dwellinghouse.

Residual Attachments, which, it is expected, will be used to arrest intellectual property, will be implemented from autumn 2009 onwards.

BANK CHARGES

The bank charges test case continues to work its way through the English legal system.

After the banks involved in the case decided to appeal the decision of the High Court, the Court of Appeal has now decided the charges can be subject to the fairness test contained in the Unfair Terms in Consumer Contract Regulations.

Although the Court refused the right to appeal, it is likely the banks will appeal directly to the House of Lords.

All cases, challenging the legality of the charges are likely to remain on hold, until the case is decided definitively.

MORTGAGE TO RENT AND SHARED EQUITY                    

Mortgage to Rent

The Scottish Government has now released details of their new Mortgage to Rent Scheme, which was launched in March 2009.

The Scheme aims to allow social landlords to take over the ownership of the homes of homeowners who are at risk of losing their property, either as a result of arrears with secured lenders or through insolvency and allow them to remain in possession as tenants.

The eligibility criteria for the Scheme will largely remain the same as before, although a list of average prices for homes throughout Scotland will be published and, other than in exceptional circumstances, it will not be possible to apply should the homeowners’ property be above the average value. The value of the property will be the value of the home, with all necessary repairs carried out to make it habitable.

A £6,000 grant will be available to the Social Landlord to carry out all necessary repairs.

If repairs, costing more than £6,000 are required, the application will only go through if the excess can be found from other sources.

Where there is equity, the debtor will be able to retain £8,000 of it, when under 60 years of age and £12,000m, when over 60 years of age. This source can be used to pay for repairs in excess of £6,000.

It will also not be possible to apply should the homeowner have more than 25% equity, unless the debtor is in a Trust Deed or has an interest only mortgage.

One important change will be that it will no longer be necessary for the home to be in imminent danger of being repossessed or for the lender to have initiated legal proceedings. Now, providing the owner has not made 3 months full payments and there are one month arrears, it will be possible to apply, providing all other UK home rescue schemes have first been exhausted.

Mortgage to Shared Equity

The Government Mortgage to Shared Equity Scheme will be similar to the Mortgage to Rent Scheme, in its’ intentions: that is to keep families in their homes. However, unlike the Mortgage to Rent Scheme, this entirely new remedy aims to allow debtors to retain some ownership of their property.

It will not be open to anyone with less than 25% equity and again debtors will need to exhaust all other UK home rescue remedies first. It will also not be available to any debtor who is insolvent, either as a result of signing a Trust Deed or applying for Sequestration.

Debtors applying for this Scheme will also need to have a capital and interest repayment mortgage.

It is intended a Government adviser will assess what level of share of the debtor’s home the Government will need to purchase, in order to reduce their monthly mortgage payments to an affordable level.

The debtor will not be required to pay rent to the Government for their share of the home. 

In order to apply for both Schemes, debtors will first need to seek advice from an agency that is a Citizen Advice Scotland or Money Advice Scotland member.

[1] http://www.aib.gov.uk/News/releases/2009/01/13215620

[2] http://www.aib.gov.uk/News/releases/2009/03/13163726

[3] http://www.aib.gov.uk/News/releases/2009/03/13114653

[4] http://www.aib.gov.uk/Resource/Doc/4/0000669.pdf

[5] Reaching for Reform, Credit in Scotland Supplement, Credit Today, issue March 2009

Money Advice Update – January 2009

Money Advice Update – January 2009

First published in the January 2009 edition of SCOLAG

Bankruptcy and Diligence Etc (Scotland) Act 2007

Although at the time of writing no draft regulations or precise dates are available, the next stage of implementation for the Bankruptcy and Diligence Etc (Scotland) Act 2007,  appears to have been delayed and will be at the end of April 2009, rather than early 2009, as initially intended.

Actions of Arrestment and Furthcoming

Previously a common law diligence, Actions of Arrestment and Furthcoming are commonly used to arrest bank accounts, but can be used to arrest any moveable property held by a third party. Soon to be almost entirely a creature of statute, the Debtors (Scotland) Act 1987 is to be amended to include the rules governing them under a new Part 3A[1].

Importantly, there will now be protection for a minimum amount held in bank accounts[2]. The amount to be protected from arrestment will be the monthly amount, under which no deduction can be made using an earnings arrestment: currently £370[3].

There will be no automatic protection for social security benefits or tax credits held in bank accounts, but a recent decision by Sheriff Principal Kearney[4], held where social security benefits and tax credits, paid into an account can be identified, it will not be possible to subject those funds to arrestment[5]. This leaves open the possibility that where benefits paid into an account exceed £370, then providing they can be identified, it may be possible to protect funds over the minimum amount.

Under the new provisions, despite the heading under Part 10 of the 2007 Act, there will no longer be an Action of Furthcoming, with funds arrested being automatically released to creditors after 14 weeks[6], unless the debtor agrees to the early release of the funds.

There will be no automatic release of property, however, where the debtor, the arrestee of a third party submits a notice of objection[7]. Notices of objection must be intimated within 4 weeks of the arrestment being executed or final decree being obtained (in the case of arrestment on the dependence). Grounds of objection are the warrant authorising the arrestment is invalid, the arrestment was executed incompetently or irregularly or the property is owned solely by the third party or in common with the debtor[8] (this could include joint accounts or funds held in trust for the maintenance of others, such as children).

Automatic release will also be prevented where a debtor or other person, who the court believes has an interest, applies for release of all or some of the funds on the grounds the arrestment is unduly harsh[9]. In considering whether the arrestment is unduly harsh, the Sheriff shall have regard to the source of the funds (possibly also that they are benefits) and whether other arrestments are already in place (including possibly earning arrestments and the fact diligence has being executed twice on the same funds).

Where a Sheriff finds an objection founded or that an arrestment is unduly harsh, he may restrict or recall the arrestment.

New provisions will also be implemented to oblige arrestees to disclose to creditors, within 3 weeks, the nature and value of the property arrested[10].

Inhibitions

New provisions will also be implemented in relation to inhibitions, which will abolish the bills and letters procedure and will include the authority to apply for an inhibition in extract decrees and documents of debt[11].

A Sheriff will also now be able to grant a warrant for diligence by inhibition, on the dependence of an action[12].

Inhibitions will also no longer confer preference in bankruptcy or insolvency proceedings[13] and will take effect from the date of recording[14].

Accountant in Bankruptcy Reviews

The awaited reviews of the Debt Arrangement Scheme and Low Income Low Asset Bankruptcies have now been published and are available from the AIB website[15].

Unfortunately, the AIB has used different geographic regions to show the number of applications being made with regards both Schemes, making any meaningful geographical comparison of use of the schemes, not possible. More importantly with regards the Debt Arrangement Scheme, it appears the AIB do not currently have figures showing the numbers of homeowners in Debt Payment Programmes. This is unfortunate, as it could reveal to what extent the DAS is being used as a remedy to protect homeowners from sequestration.

Where it would appear LILAs have been a huge success, with over 2,929 debtors applying for bankruptcy using the route between April and July 2008, the Debt Arrangement Scheme has not been as successful, although take up has significantly increased since June 2007 (a five fold increase on that of the previous year).

Significant emphasis continues to be placed by DAS Administrator on the problem of lengthy payment programmes (23% of the cases in the review period are expected to last more than 10 years), but this may only reflect the fact that for an increasing number of debtors, other than surrendering their homes and possibly making themselves and their family’s homeless, such programmes are the only option available.  Again the lack of figures regarding homeownership by debtors in DPPs appears to be a missed opportunity to understand use of the scheme.

The main concern with DAS remains its accessibility for debtors, with, in the review period, no DPPS being applied for or approved in 7 local authority regions.

The AIB has proposed a number of options for the DAS. The options outlined in the review are: do nothing and allow it to continue; abolish it; introduce composition (which could address the issue of DPPs which will last beyond 10 years); the AIB taking over the administration of cases and finally the AIB taking over the administration of cases and removing the need for debtors to apply through Approved Money Advisers.

With regards the last two options, the concept of debtors applying themselves seems unrealistic, when it is considered one of the issues most commonly raised by approved money advisers is that the application process is complex and time consuming.

With regards the DAS Administrator taking over the administration of cases, this may have merit if it was to reduce the workload on approved money advisers. The problems remains, however, the majority of work on cases is at the set-up stage and in carrying out variations. It is likely this work would still have to be carried out by money advisers and, therefore, the benefits of the work being taking in house seem negligible.

The reality is, the problem with DAS is not that it is an unattractive option to some debtors, although introducing composition could make it more so, but there is difficulty in accessing it. Considering the fifth option of removing approved money advisers as a gateway to the scheme is not realistic and in reality money advisers would still need to make most of the applications for debtors, as they currently do for LILA, the issue of increasing the number of approved money advisers remains the only plausible option.

Furthermore, as increasing measures are being taken by both the UK and Scottish Government to protect homeowners from repossession, DAS remains the only credible options open to those with multiple debts facing sequestration and protects them from losing their homes. Indeed, it would seem ridiculous to increase protection for debtors from secured lenders, only for them to lose their home through the actions of unsecured lenders.

Abolition of the Scheme, in these times, cannot, therefore, be a serious option..

In light of this, one suggestion is to leave the rules governing it intact and focusing on increasing access through increasing numbers of approved money advisers.

If any changes to the Scheme should be considered, possibly one is that the current procedure, which allows a debtor to intimate an intention to apply for a DPP and obtain six weeks protection from sequestration, should be increased to six months. This would allow those who can demonstrate a significant drop in income to safeguard their homes, for a period, whilst seeking new employment or methods to increase their income.

It is expected any changes that are introduced, however, will be introduced by June or July 2009 and left unchanged for 5 years to allow them to bed in.

Time to Pay Directions/Orders

Council Tax and Summary Warrants

There appears to be some confusion with regards time to pay measures under the Debtors (Scotland) Act 1987 and their use with regards Council Tax. Prior to April 2008, neither remedy was competent in relation to a debt constituted by Summary Warrant, but now is in relation to Council Tax.

Despite the legislation and explanatory notes to the 2007 Act, suggesting Time to Pay Directions are competent with regards council tax debt, the summary warrant procedure does not allow an application to be made.

Debtors have to wait until a Charge for Payment is served and then they are able to apply for a Time to Pay Order. The detriment to the debtor is this results in them incurring the cost of the charge being served, whereas if they were able to apply earlier, as intended, the further expense could be avoided.

Transferring Powers to Award Proposed

Indications are that the Accountant in Bankruptcy will now be proposing to the Scottish Government that she takes over the role of granting Time to Pay Directions/Orders under the Debtors (Scotland) Act 1987.

It is probably to be welcomed the possibility of removing these remedies from the adversarial environment of the courts and it would make the process of applying, less stressful for debtors.

It raises the issue, however, whether the AIB are now taking on a judicial role.  They now award sequestration, when debtors’ apply, where previously this was the role of the courts. If they are to take over the role of awarding Time to Pays, will this also mean  decrees, which when currently granted by the courts results in an instalment decree. It also begs the question what will happen when debtors wish to dispute the level of their liability and apply for a Time to Pay. Will the AIB adjudicate on these issues or will the courts retain authority on these matters? A further issue is whether debtors or their representatives, will retain the right to make oral representations, as they can currently in front of a Sheriff, or whether that right will be lost? Importantly it will need to be clarified whether the process will remain free to debtors.

With the proposed changes to the DAS, this could see a huge increase in the role of the AIB.

There clearly needs to be proper discussions as to whether this possible increased role is in the wider pubic interest and whether it is appropriate that a government agency takes on such judicial functions. If they take over the role of deciding time to pays under the Debtors (Scotland) Act 1987, why not Time Orders under the Consumer Credit Act 1974 or S2 orders under the Mortgage Rights (Scotland) Act 2001?

Historically, the AIB’s expertise has been in Insolvency and case administration, not in the provision of advice and performing what were previously, judicial functions. If the AIB is to take on wider roles, such as this, there must be more transparency in their decision making process: not just providing guidelines for advisers, but also publishing the detailed guidance they make available to their decision makers.


[1] Section 206, Part 10 of the Bankruptcy and Diligence Etc (Scotland) Act 2007

[2] S73F Debtors (Scotland) Act 1987 (as amended) – when S206 of the 2007 act is commenced

[3] Table B, The Diligence Against Earnings (Variation) (Scotland) Regulations 2006

[4] North Lanarkshire Council v Shirley Crossan & Airdrie Savings Bank, unreported, Airdrie Sheriff Court 2nd May 2008 see: http://www.govanlc.com/nlc-crossan-judgment.pdf

[5] Although the case Sheriff Principal Kearney decided dealt with arrestments under the common law, the case concerned the inalienability of benefits under S187 of the Social Security Administration Act 1992 and S45 of the Tax Credits Act 2002. It is likely, therefore, the decision may still be relevant for the new arrestments.

[6] S73J Debtors (Scotland) Act 1987 (as amended) – when S206 of the 2007 act is commenced

[7] S73L Debtors (Scotland) Act 1987 (as amended) – when S206 of the 2007 act is commenced

[8]  S73M Debtors (Scotland) Act 1987 (as amended) – when S206 of the 2007 act is commenced

[9] S73Q Debtors (Scotland) Act 1987 (as amended) – when S206 of the 2007 act is commenced

[10] S73G Debtors (Scotland) Act 1987 (as amended) – when S206 of the 2007 act is commenced

[11] S146, Bankruptcy and Diligence etc (Scotland) Act 2007

[12] S15A Debtors (Scotland) Act 1987 (as amended) – when S169of the 2007 act is commenced

[13] S154, 2007 Act

[14] S149 2007 Act

[15] www.aib.gov.uk