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       #Post#: 21982--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: May 9, 2024, 12:56 pm
       ---------------------------------------------------------
       --- Quote from: _wooky_ link ---
       >
       > We're still trying to dig out a copy of the contract hire
       document. The only thing we've seen so far that references fines
       is in a summary letter after we took delivery of the car...
       >
       --- End Quote ---
       But you haven't been "fined" at all. All you received was a
       speculative invoice from an unregulated private parking company
       for an alleged breach of contract by the the driver of the
       vehicle. I'll give you £100 for every occurrence of the word
       "fine" in any of the correspondence you've received from the
       parking company.
       Only a "penalty" charge is a "fine" and only an "authority" such
       as a council or the police can issue "fines". An ex-clamper thug
       setting up a private parking company is not an "authority" and
       cannot issue "fines".
       So, you were not "fined" at all. UKPC has failed to provide the
       necessary documents with the NtH which would allow it to pass
       the charge on to the hirer as required under PoFA 14(2)
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4/enacted.<br
       />UKPC don't know the identity of the driver and you are under
       no
       legal obligation to give them that information. They cannot hold
       you, the keeper liable.
       Unfortunately, it is too late to appeal and so you have also
       missed the opportunity to appeal to POPLA. No big deal.
       You must now ignore all debt collection letters. ZZPS, their
       sister company GCTT and QDR solicitors are all scammers/cowboys
       who can be safely ignored. None of them have any skin in the
       game and are third parties to the contract the driver allegedly
       breached. They can do nothing except try and scare the
       low-hanging fruit on the gullible tree into paying into their
       scam.
       UKPC may, at some stage, instruct one of the roboclaim
       solicitors, usually DCB Legal or will do so themselves from
       their own, recent but inexperienced and intellectually
       malnourished internal "legal department", a Letter of Claim.
       If/when they issue a Letter of Claim, come back and we'll advise
       on a response.
       Until that happens, there is nothing else you can do except
       weather the useless storm of debt collector letters. Some people
       use them as liner for their bottom of a cat litter tray or as
       kindling.
       The only other suggestion I can make is that you make a
       complaint (not an appeal) as the keeper to UKPC advising them
       that they have failed to issue the NtH in accordance with the
       requirements of PoFA 14(2) and
       so cannot hold you, the keeper liable. This is also a breach of
       the BPA CoP 21.2 which states:
       --- Quote ---
       > Schedule 4 of POFA 2012 creates the new legal basis to claim
       unpaid parking charges from vehicle keepers and hirers. As long
       as the strict conditions of Schedule 4 are met, you may claim
       payment from the keeper or the hirer of the vehicle rather than
       from the driver. To do this you need to follow the procedures
       set out in the Schedule. You can do this whether the parking
       originally took place under the terms of a contract or was an
       act of trespass.
       --- End Quote ---
       Depending on their response, you could then report them to the
       BPA for contravening their own ATA rules. They have failed to
       comply with the requirements of rule 21.2 because they have
       failed to follow the strict conditions of PoFA 14(2).
       #Post#: 21998--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: _wooky_
       Date: May 9, 2024, 3:58 pm
       ---------------------------------------------------------
       Brilliant. Great advice, thanks &#128591;&#10084;&#65039;
       --- Quote from: b789 link ---
       >
       >
       > The only other suggestion I can make is that you make a
       complaint (not an appeal) as the keeper to UKPC advising them
       that they have failed to issue the NtH in accordance with the
       requirements of PoFA 14(2) and
       > so cannot hold you, the keeper liable. This is also a breach
       of the BPA CoP 21.2 which states:
       >
       >
       --- End Quote ---
       To clarify, we're the hirer, not the keeper. Not sure the above
       applies in that case.
       Thanks again.
       #Post#: 22000--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: DWMB2
       Date: May 9, 2024, 4:01 pm
       ---------------------------------------------------------
       The argument and the relevant section of PoFA is right, just
       replace 'keeper' with 'hirer' and the argument still stands
       #Post#: 22007--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: May 9, 2024, 6:13 pm
       ---------------------------------------------------------
       Hirer/keeper have the same protection under PoFA. Just change
       “keeper” to “hirer” or “hirer/keeper”.
       #Post#: 22017--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: slapdash
       Date: May 10, 2024, 2:35 am
       ---------------------------------------------------------
       [member=1601]_wooky_[/member]
       VWFS had a policy where they would simply pay a second invoice
       if received and recharge it to the hirer. It doesn't look as
       though they are likely to do this given you have had a debt
       collector letter.
       They use different agreements for PCH and PCP. Their recent
       contract hire agreement included the words "or charges". (At
       least the one I have seen does)
       (Your description suggests the vehicle is PCH, however the
       fragment you posted looks like a PCP, though it does mention
       they tax it which is a PCH thing).
       If they do happen to pay it a different approach will be needed.
       #Post#: 22038--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: H C Andersen
       Date: May 10, 2024, 5:37 am
       ---------------------------------------------------------
       Aren't we off-course.
       The creditor is UKPC, not Skoda.
       I cannot find anything in Skoda's correspondence which suggests
       they'll make any financial demands upon you other than they
       receive a 'second notification'.
       But IMO you have no reason to think they will because:
       UKPC have sent you a NTH;
       And a Final Demand;
       And an unseen letter(from a 'debt collector').
       IMO, ignore Skoda* as regards the NTH, they're a distraction
       from what you should be doing which is appealing/writing to
       UKPC.
       Apparently the UKPC we site won't let you appeal.
       None the less, you should write to them and appeal.
       Why?
       Because it's what a normal motorist would do who has taken the
       time to establish the relative legal positions of the creditor
       and hirer and discovered that the creditor may not legally
       pursue the hirer of the car as hirer. The hirer then should
       communicate this to the creditor at the earliest possible
       opportunity. You can't do this online, so write to them.
       In effect, the hirer would be setting out their cast-iron
       defence to prevent the creditor incurring unnecessary and
       irrecoverable costs by continuing to pursue the matter.
       The legal position as I see it:
       Failure to provide the mandatory docs under para. 14 to Schedule
       4;
       Failure to state correct practically all the mandatory periods
       and conditions applicable under para. 4 as regards having the
       right to enforce against the hirer.
       *-if Skoda do write, then come back.
       **- read para. 4 and see what a NTH should contain:
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4/enacted
       #Post#: 22045--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: slapdash
       Date: May 10, 2024, 6:32 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Aren't we off-course.
       >
       > The creditor is UKPC, not Skoda.
       >
       --- End Quote ---
       Yes, but ....
       I did not say VWFS will pay it.
       I did say, by policy, VWFS have a habit of paying any second
       invoice - irrespective of whether they have any contractual
       right to do so (and irrespective of whether they have any actual
       obligation).
       The result of that is, in effect:-
       "You can't do that".
       "We just did, your move".
       Thus, *if* VWFS do act as they have often done, op needs a
       different approach because they then have a contractual dispute
       with VWFS instead.
       #Post#: 22046--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: DWMB2
       Date: May 10, 2024, 6:42 am
       ---------------------------------------------------------
       --- Quote from: slapdash link ---
       >
       > Thus, *if* VWFS do act as they have often done, op needs a
       different approach because they then have a contractual dispute
       with VWFS instead.
       >
       --- End Quote ---
       Indeed, but so that this thread does not get unduly sidetracked
       by an issue that may not emerge, I suggest we cross that bridge
       if we come to it, and for now focus on the OP's dispute with
       UKPC.
       #Post#: 22047--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: May 10, 2024, 6:53 am
       ---------------------------------------------------------
       In their contract, a &#8220;parking charge&#8221; cannot come
       under the heading of &#8220;Fines&#8221;.
       Trying to appeal this with UKPC is an exercise in futility. I
       have already told the OP to complain to UKPC, pointing out that
       they cannot be liable for the charge as the hirer and that UKPC
       have breached their ATA CoP by failing to adhere to the
       requirements of PoFA for the reasons stated.
       UKPC either cancel the PCN or they are then reported to the BPA
       with the details. The BPAs response will then determine the next
       steps. The BPA will not do anything until the complaints
       procedure with the operator has been exhausted.
       Additionally, the OP has received the NtH so liability has been
       transferred away from VWFS. UKPC cannot go back to them with
       another invoice. Even if they did, the OP would have a rock
       solid claim against them if they then went ahead and paid it.
       #Post#: 22048--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: slapdash
       Date: May 10, 2024, 6:56 am
       ---------------------------------------------------------
       I wasn't trying to sidetrack merely alert the possibility of
       having to change direction. Fwiw my sons experience was 2 he
       ignored VWFS just paid (he got the "policy" letter. 1 he
       appealed went to debt collection etc. The likely trigger for the
       difference is obvious.
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