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       #Post#: 59687--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: kgw Date: February 25, 2025, 1:02 pm
       ---------------------------------------------------------
       Oops, I read too quickly.
       So their defence is very lousy.
       I've posted the comments nd got this:
       "Your appeal is now ready to be assessed and is currently in a
       queue waiting to be allocated. We expect to make a decision on
       your appeal 6-8 weeks from the point that the appeal was first
       submitted. The next communication that you will receive from us
       will be the decision on your appeal."
       Thanks.
       #Post#: 70544--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: kgw Date: May 8, 2025, 8:49 am
       ---------------------------------------------------------
       Hi,
       The POPLA appeal has been unsuccessful. They consider the NtK to
       be PoFA, PPSCoP compliant.
       Assessor summary of your case
       The appellant has raised the following grounds of appeal: • The
       contradiction in payment deadlines renders the Notice to Keeper
       Non-Compliant with Protection of Freedom Act 2012. • There is
       further Notice to Keeper Non-Compliance and the operator has not
       established driver liability and cannot hold the keeper Liable.
       • The Notice to Keeper contains misleading information,
       contradicting the BPA/IPC Private Parking Single Code of
       Practice (Effective Since October 2024). • ParkMaven’s appeal
       rejection references a defunct BPA Code of Practice. • There is
       inadequate signage – No Contract Formed with the Driver. • There
       is no evidence of landholder authority. The appellant has
       expanded on their grounds of appeal in the comments and they say
       that the operator has not rebutted their grounds of appeal
       regarding PoFA compliance. They say that the evidence provided
       regarding landowner authority is not sufficient. The appellant
       has provided a document with their full grounds of appeal.
       Assessor supporting rational for decision
       When assessing an appeal POPLA considers if the operator has
       issued the parking charge notice correctly and if the driver has
       complied with the terms and conditions for the use of the car
       park. The operator has provided evidence of the vehicle parked
       on the site for one hour and 22 minutes on the day in question.
       The Protection of Freedoms Act (PoFA) 2012 is a law that allows
       parking operators to transfer the liability to the registered
       keeper in the event that the driver or hirer is not identified.
       Parking operators have to follow certain rules including warning
       the registered keeper that they will be liable if the parking
       operator is not provided with the name and address of the
       driver. In this case, the PCN in question has the necessary
       information and the parking operator has therefore successfully
       transferred the liability onto the registered keeper. In this
       case, it is not clear who the driver of the appellant’s vehicle
       is, so I must consider the Protection of Freedoms Act (PoFA)
       2012, as the operator issued the Parking Charge Notice (PCN) to
       the keeper of the vehicle. The operator has provided me with a
       copy of the notice to keeper sent to the appellant. I have
       reviewed the notice to keeper against the relevant sections of
       PoFA 2012 and I am satisfied that it is compliant. I will
       therefore be assessing keeper liability. I note that the
       appellant has mentioned that the timelines on the PCN are not
       PoFA compliant however it is important to be aware that there
       will be a reference to the dates the operator expects payment to
       be made. This is in the event the motorist does not wish to
       appeal the PCN and pays it. The timescales referred to in the
       PoFA paragraph are to transfer liability in the event the driver
       is not identified and are not for making payment. The appellant
       has advised that the operator has mentioned a defunct code of
       practice in the evidence pack. Whilst I understand what the
       appellant means this does not invalidate the reason for issuing
       the PCN. The appellant will need to contact the operator
       directly to discuss this. The sector Code of Practice has been
       jointly created by the British Parking Association (BPA) and the
       International Parking Community (IPC). It is largely based on
       the Government’s Private Parking Code of Practice, which was
       published in February 2022, and subsequently withdrawn in June
       2022. The new Code came into force on the 1 October 2024. It is
       stipulated in the Code that the parking operator needs to comply
       with all elements relating to signage by 31 December 2026.
       Therefore, for any aspects of this case relating to signage, I
       will be referring to version 9 of the BPA Code of Practice. This
       is applicable for parking events that occurred from 1 February
       2024. The British Parking Association (BPA) has a Code of
       Practice which set the standards its parking operators need to
       comply with. Section 19.3 of the code states that signs must be
       placed throughout the car park so that drivers have the chance
       to review the terms and conditions. The code confirms that these
       signs must be conspicuous and legible and written in
       intelligible language so that they are easy to see read and
       understand. The operator has provided a site map and multiple
       images of the signs within the car park and after reviewing
       these, I am satisfied that there are plenty of signs located
       within the car park and that these signs meet the requirements
       of section 19.3 of the Code of Practice. These signs advise that
       payment is required and that failing to pay will result in a PCN
       being issued. I note that the appellant states that they were
       unaware of the terms and conditions, however, it is important to
       note that the driver of the vehicle does not need to have read
       the terms and conditions of the contract to accept it. There is
       only the requirement that the driver is afforded the opportunity
       to read and understand the terms and conditions of the contract
       before accepting it. It is the driver’s responsibility to seek
       out the terms and conditions, and ensure they understand them,
       before agreeing to the contract and parking. Reviewing the
       photographic evidence of the signage on display at the site and
       the site map, I am satisfied that the driver would have walked
       or driven past at least one of the operator’s signs and as such,
       was afforded this opportunity. The appellant states that there
       is no landowner authority and to address this I will be
       referring to The Private Parking Sector Single Code of Practice
       (The Code) which sets the standards its parking operators need
       to comply with. Section 14.1 of the Code states that where
       controlled land is being managed on behalf of a landowner,
       written confirmation must be obtained before a parking charge
       can be issued. In this case the operator has provided a witness
       statement and an enforcement agreement and I am satisfied that
       the operator has the authority to issue PCN’s on this site. The
       operator does not need to provide a full copy of the full
       contract as it may contain commercially sensitive information.
       While I note the appellant’s comments, from the information
       provided from the operator I am satisfied therefore, that the
       operator had sufficient authority on the date of the
       contravention. Furthermore, if authority had since been removed,
       it is likely that the landowner would remove the signage at the
       same time. Not many landowners would look on quietly while
       someone operates on their land without their permission. The
       evidence provided in relation to this appeal meets the criteria
       POPLA requires, and therefore I am satisfied that the operator
       has sufficient authority at the site on the date of the parking
       event. After considering the evidence from both parties the
       driver had parked on the site and did not obtain a valid parking
       session and therefore did not comply with the terms and
       conditions of the site. Based on the evidence provided, I am
       satisfied the parking charge has been issued correctly
       therefore, I must refuse the appeal. This means the appellant is
       required to pay the full parking charge to the operator.
       Was this to be expected ? I guess the next step is in court...
       :(
       #Post#: 70593--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: b789 Date: May 8, 2025, 2:55 pm
       ---------------------------------------------------------
       Court is not the most likely outcome. Whilst they will probably
       issue a claim, in due course, the odds of it actually ever
       reaching hearing are slim and even if it did, your case is
       strong.
       Do not pay this. The POPLA decision is not binding on you. Which
       POPLA assessor came up with this tripe? It is not a secret and
       their names are in the public domain.
       I would suggest a formal complaint to POPLA about this assessors
       utter lack of competence. It won't change the decision but it
       does establish a paper trail for formal complaints which can
       later be relied on as evidence of their failings.
       There are five obvious failings by this assessor:
       1. Misunderstanding of PoFA 9(2)(f)
       The assessor wrongly asserts:
       [indent]"The timescales referred to in the PoFA paragraph are to
       transfer liability… and are not for making payment."[/indent]
       This is incorrect. PoFA 9(2)(f) expressly governs the 28-day
       period within which the Keeper is liable unless the driver is
       named. That period starts the day after the NtK is given, as per
       9(2)(f):
       [indent]"Warn the keeper that if… after the period of 28 days
       beginning with the day after that on which the notice is
       given…"[/indent]
       A statement on the front of the NtK demanding payment by a date
       calculated from the issue date, not the day after the date of
       deemed delivery, is not PoFA-compliant. This is not about
       operator preference or flexibility—PoFA compliance is strict.
       The assessor erred in law by implying the misleading payment
       deadline has no bearing on keeper liability.
       2. Total Ignorance of PoFA 9(2)(e)(i)
       It was clearly explained that the NtK:
       [indent]• Does not invite the Keeper to pay the charge.
       • Merely demands that the driver pay and requests the Keeper to
       name them.[/indent]
       PoFA 9(2)(e)(i) requires an explicit invitation to the Keeper:
       [indent]“State that the creditor does not know both the name of
       the driver and a current address for service and invite the
       keeper to pay the unpaid parking charges.”[/indent]
       The assessor ignored this completely. There is no lawful basis
       for transferring liability if this required element is missing.
       POPLA failed to assess the core condition for keeper liability.
       3. Dismissal of PPSCoP Breach as Irrelevant
       PPSCoP 8.1.2(e) was referenced, which says:
       [indent]“The recipient can appeal within 28 days of receiving
       the parking charge.”[/indent]
       And its Note 2 clarifies:
       [indent]“…presumed to have been delivered on the second working
       day…”[/indent]
       Again, the assessor missed the point: The NtK’s deadline
       shortens the Keeper’s rights under the PPSCoP, a breach of the
       operative Code. Their statement that operators “may refer to
       payment dates” misses the central issue: the NtK actively
       contradicts the statutory wording, misleading the recipient.
       POPLA’s own remit includes enforcing the current Code of
       Practice, and they failed to uphold this.
       4. Failure to Require Landowner Contract With Sufficient Proof
       ParkMaven’s evidence was challenged:
       [indent]• Undated, unsigned, or post-dated signatures.
       • Contradictory claims about confidentiality.
       • Absence of confirmation that the signatory is the landowner or
       authorised agent.[/indent]
       The assessor ignored all this and instead relied on a generic
       “witness statement”, despite DVLA guidance and case law
       confirming that the contract must be current, valid, and
       sufficiently prove the operator’s legal standing.
       Their logic that "the signage would have been removed if the
       contract wasn’t in force" is a laughable assumption not based on
       evidence.
       5. POPLA Breached its Own Principles
       The appeal stated:
       [indent]"Under POPLA’s own appeal assessment principles, if an
       appellant raises a valid challenge and the operator does not
       respond to it, the appeal must be upheld."[/indent]
       That is a long-standing principle, repeated by assessors in
       countless past decisions. In this case:
       [indent]• The operator did not address PoFA 9(2)(f)
       • The operator did not rebut 9(2)(e)(i)
       • The operator did not address the PPSCoP deadline breach
       • The operator did not refute the BPA CoP error in their appeal
       response[/indent]
       The burden is on the operator to respond to every point. POPLA’s
       failure to apply this basic standard is a dereliction of duty.
       Send the following complaint to POPLA:
       [quote]Subject: Formal Complaint Regarding Failed Appeal –
       Verification Code [INSERT CODE] – Escalation Required
       To whom it may concern,
       This is a formal complaint regarding the decision issued by
       POPLA under verification code [INSERT CODE] for a Parking Charge
       Notice issued by ParkMaven. This complaint must be escalated to
       the most senior level of POPLA management. I also confirm that
       it is being forwarded to my Member of Parliament due to the
       systemic failings this decision exposes.
       Let me be clear: I am not writing this complaint in the
       expectation that the decision will be overturned. I am fully
       aware that POPLA does not permit assessors to reverse an appeal
       decision, no matter how legally flawed it is. That is itself
       part of the problem and will be raised with the relevant
       government department and Parliament.
       I expect this complaint to be logged, responded to in writing,
       and used to review the training and competence of the assessor
       involved, who has demonstrated a complete inability to apply
       basic statutory requirements or read the appeal they were tasked
       to assess.
       1. Blatant misinterpretation of PoFA 2012 – Paragraph 9(2)(f)
       My appeal detailed that ParkMaven's Notice to Keeper (NtK)
       contradicts the statutory wording of PoFA Schedule 4, Paragraph
       9(2)(f) by demanding payment "within 28 days of the date issued"
       – a full six days earlier than legally allowed. This is not a
       minor technicality. It is a material legal failure.
       PoFA is clear: the 28-day period begins "with the day after that
       on which the notice is given." "Given" means delivered, and PoFA
       9(6) deems it to be two working days after posting. The NtK in
       this case was issued on 24/12/2024, with deemed delivery on
       30/12/2024. The front of the NtK misleadingly sets the deadline
       as 21/01/2025 instead of the correct 27/01/2025.
       This is an outright breach of PoFA. The assessor waved it away
       with the astonishing claim that payment deadlines "are just for
       those who do not wish to appeal" – as if the statutory
       provisions are optional. This statement is legally indefensible
       and demonstrates a lack of basic understanding of how liability
       is created under Schedule 4.
       2. Ignoring the absence of PoFA 9(2)(e)(i) wording
       I highlighted that the NtK does not contain the required
       invitation for the keeper to pay the charge, as mandated by PoFA
       9(2)(e)(i). Instead, the NtK only demands payment from the
       driver and asks the keeper to name the driver if not them.
       PoFA requires an express invitation to the keeper to pay the
       charge. The assessor completely ignored this point, made no
       reference to paragraph 9(2)(e)(i), and failed to engage with the
       most basic requirement for keeper liability.
       This is not an oversight. It is a gross failure of professional
       standards by someone apparently untrained or unwilling to read
       and apply the law they are tasked with assessing.
       3. Dismissal of PPSCoP breach and misrepresentation of
       transitional arrangements
       I explained in my appeal that the NtK breaches the Private
       Parking Single Code of Practice (PPSCoP), which has been in
       force since October 2024. Section 8.1.2(e) makes it crystal
       clear:
       [indent]"The recipient can appeal within 28 days of receiving
       the parking charge."[/indent]
       The word "receiving" is not open to interpretation. The
       accompanying note defines it clearly as two working days after
       posting. Despite this, the operator falsely shortened the
       deadline to 21/01/2025. This is a material misrepresentation of
       the keeper's rights and a direct breach of the Code.
       The assessor showed either ignorance or laziness by brushing
       this aside and claiming the PPSCoP only applies to signage until
       2026. That is completely wrong. The signage deadline relates
       only to physical compliance by operators, not to the immediate
       obligations concerning transparency, wording, and deadlines in
       written communications.
       This failure to understand the Code and apply its provisions
       brings POPLA’s own credibility into question.
       4. Failure to uphold POPLA’s own standards regarding operator
       rebuttals
       In at least five distinct areas of my appeal, the operator
       failed to respond:
       [indent]• No rebuttal of PoFA 9(2)(f) or 9(2)(e)(i) points
       • No response to the PPSCoP breach
       • No defence of the use of the defunct BPA Code of Practice in
       the rejection letter
       • No evidence justifying the misleading keeper liability claim
       •No explanation for the flawed and post-dated contract provided
       as landowner authority[/indent]
       POPLA has long held that if an operator does not rebut a
       specific appeal point, the appeal should be upheld. Yet in this
       case, the assessor simply pretended that none of these failures
       occurred. That is dishonest, unacceptable, and contrary to
       POPLA’s own published assessment standards.
       5. Acceptance of dubious “contract” evidence
       I challenged the validity of the landowner authority. ParkMaven
       submitted a document:
       [indent]• Signed five months after the contract was supposedly
       in force
       • With no signature by ParkMaven
       • With no verification of the signatory’s position
       • While simultaneously claiming the contract was “too
       confidential” to disclose (and then disclosing it
       anyway)[/indent]
       The assessor accepted this without comment, justification, or
       applying a basic evidential standard. This undermines the
       fairness of the process and renders it a tick-box exercise
       unworthy of public trust.
       Request for POPLA Management Action
       This complaint must be passed to POPLA senior management. I
       expect:
       [indent]• A written response explaining what went wrong in this
       case
       • An explanation of what additional training or disciplinary
       review the assessor will undergo
       • A confirmation that these failures will be raised internally
       and used to prevent recurrence[/indent]
       This complaint is being escalated to my Member of Parliament,
       not because POPLA has any regulatory or statutory function (you
       don’t), but because the public is entitled to expect basic
       competence from bodies purporting to offer an independent appeal
       service. This appeal was handled with a level of carelessness
       and legal illiteracy that is unacceptable, and it is important
       that decision-makers at a national level are made aware of the
       standards being applied behind the curtain of POPLA's
       “independence”.
       POPLA is a private contractor, funded by the BPA, with no legal
       authority, no accountability mechanism, and no appeals process
       once a decision is issued. That makes it all the more important
       that decisions are made accurately, transparently, and lawfully
       the first time—none of which occurred here.
       This complaint is not about overturning the outcome. I know how
       your process works. It is being made for the record, and to
       require a formal written explanation of:
       [indent]• Why key appeal points were ignored or dismissed
       without engagement
       • What corrective action, training, or accountability will
       follow
       •Confirmation that this complaint is being reviewed by senior
       management, not just closed out by a front-line team[/indent]
       A copy of this email has been retained and will be used to
       inform others, including the press and advocacy groups, who are
       increasingly concerned about the quality, independence, and
       legal competence of POPLA’s decision-making.
       Sincerely,
       [Your Full Name]
       [Your PCN Reference Number]
       POPLA Verification Code: [Insert Code]
       Email: [Your Email]
       Address: [Your Postal Address][/quote]
       And make a complaint about this to your MP.
       #Post#: 70599--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: kgw Date: May 8, 2025, 3:33 pm
       ---------------------------------------------------------
       Thanks a lot for this.
       The assessor is Gayle Stanton.
       I agree with all your points and was amazed at none of the
       arguments were upheld.
       I find 5 to be the most damning. Maybe the assessor considered
       that the points raised about  PoFA 9(2)(f), 9(2)(e)(i), the
       PPSCoP deadline breach and the BPA CoP error were ALL invalid...
       Btw, I searched on the POPLA site but could not find reference
       to the "if an appellant raises a valid challenge and the
       operator does not respond to it, the appeal must be upheld"
       policy.
       My MP is busy promoting legislation banning kitchen knives so
       not sure what he'll do here.
       First time this happens to me. I'm learning.
       #Post#: 70821--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: kgw Date: May 10, 2025, 1:18 pm
       ---------------------------------------------------------
       POPLA sent a "how did we do ?" questionnaire. Lol
       I did not use it as they have a complaint page on their website:
       [attachimg=1]
       [attachment deleted by admin]
       #Post#: 70860--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: b789 Date: May 10, 2025, 5:37 pm
       ---------------------------------------------------------
       It is a standard and fair principle in any adjudication process
       that if a party raises a prima facie valid point, and the
       opposing party fails to respond or rebut it, that point is
       ordinarily taken as conceded or accepted. POPLA's process is
       based on the written representations of both parties.
       Therefore, where an appellant raises a challenge—such as a
       defect in the Notice to Keeper, lack of standing, or
       insufficient signage—and the operator fails to address or refute
       it in their evidence pack, the adjudicator must reasonably
       accept the appellant’s position as unchallenged. The burden
       rests with the operator to demonstrate the charge is valid and
       enforceable. If they fail to engage with a relevant appeal
       ground, they have failed to discharge that burden.
       This aligns with general adjudicative practice and is reflected
       in past POPLA decisions where appeals were upheld on the basis
       that specific challenges went unanswered by the operator.
       #Post#: 70863--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: kgw Date: May 10, 2025, 5:56 pm
       ---------------------------------------------------------
       Thanks.
       I thought this rule appeared explicitly in their literature, but
       it does not.
       They do say:
       Assessors will make decisions based on:
       - Relevant law
       - The British Parking Association's code of practice
       - Evidence provided by both parties
       And further, they dare say: "Assessors have been trained on
       these areas and our decision-making guidelines. They have also
       passed an accreditation process following our training programme
       and receive regular internal quality audits as well as coaching
       and personal development."
       Obviously very far from reality.
       I've just written to my MP.
       #Post#: 70873--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: H C Andersen Date: May 11, 2025, 4:24 am
       ---------------------------------------------------------
       ?
       PoFA para. 9 is often misunderstood.
       IMO, as far as is relevant to the point trying to be made
       regarding non-compliance:
       Payment period less than the 9(2)(f) trigger date is OK;
       Payment period equal to the 9(2)(f) trigger is OK;
       Payment period more than the 9(2)(f) trigger is not compliant.
       9(2)(f) is a statement regarding a legal power, it is not a
       payment requirement as such. These are (b), (c) and (d).
       That (f) is contingent upon, among other matters, full payment
       not having been made does not mean that other requirements which
       specify by when the creditor wants payment in accordance with
       the on-site contractual requirements must align exactly with
       this trigger but, as stated above, the payment period should not
       exceed the 9(2)(f) trigger date.
       And it doesn't.
       #Post#: 70938--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: kgw Date: May 11, 2025, 12:35 pm
       ---------------------------------------------------------
       I'm no expert but I feel like I have to analyse this like a high
       court judge.
       Strictly speaking, the NtK complies with 9(2)(f) because, in the
       fine print on the 2ᶮᵈ page, the PoFA paragraph
       states exactly what it should:
       You are advised that if, after the period of 28 days beginning
       with the day after that on which the notice is given (which is
       presumed to be the second working day after the Date Issued),
       the parking charge has not been paid in full and we do not know
       both the name and current address of the driver, we have the
       right to recover any unpaid part of the parking charge from you.
       The question is whether the prominent
       [center]PAYMENT TO BE MADE WITHIN 28 DAYS OF THE DATE ISSUED: BY
       21/01/2025[/center]
       at the top of the 1ˢᵗ page renders the NtK
       non-compliant, bearing in mind that the PoFA deadline was 6 days
       later.
       The assessor's reasoning:
       "there will be a reference to the dates the operator expects
       payment to be made. This is in the event the motorist does not
       wish to appeal the PCN and pays it. The timescales referred to
       in the PoFA paragraph are to transfer liability in the event the
       driver is not identified and are not for making payment."
       makes little sense.
       The 1ˢᵗ page statement appears to be contradictory
       but the law lists what the NtK must include, not what it must
       not.
       Asking the keeper to pay before the PoFA deadline (without
       stating consequences) can't hurt. If on the other hand the
       1ˢᵗ page had prominently mentioned a date beyond the
       PoFA deadline, while still quoting 9(2)(f) in the fine print,
       this could have tricked the keeper into unlawful territory. So I
       can see how this would be non-compliant whereas the misleading
       Parkmaven NtK complies.
       On the other hand
       9(2)(b) states that
       The notice must (...) inform the keeper that (...) the parking
       charges have not been paid in full
       I don't see that on the NtK.
       9(2)(e) states that:
       "The notice (...) must (...) invite the keeper
       (i)to pay the unpaid parking charges; or
       (ii)if the keeper was not the driver of the vehicle, to notify
       the creditor of the name of the driver and a current address for
       service for the driver and to pass the notice on to the driver"
       The NtK complies with 9(2)(e)(ii) bit, not (i) as far as I can
       see. The alternative "pay or tell us who the driver was" is
       nowhere to be seen. Incidentally, 9(2)(f) makes no sense without
       the correct 9(2)(e) wording.
       Finally, 9(2)(i) states that:
       The notice (...) must (...) specify the date on which the notice
       is sent (where it is sent by post)
       and they only provide a date of issue (ie printing). On 24
       December, this can make a difference. Maybe the whole Parkmaven
       office was on holiday from 24 afternoon.
       #Post#: 70945--------------------------------------------------
       Re: Parkmaven NtK and unsuccessful appeal
       By: b789 Date: May 11, 2025, 1:07 pm
       ---------------------------------------------------------
       The NtK in question technically complies with Paragraph 9(2)(f)
       by including the correct statutory wording. However, it may
       still be non-compliant with PoFA as a whole because the notice
       introduces ambiguity by setting a prominent “payment deadline”
       that contradicts the PoFA-prescribed timeline. This undermines
       the effectiveness of the statutory warning and fails the test of
       clarity required under PoFA, rendering the notice unsuitable for
       transferring liability to the keeper.
       Also, the NtK is misleading and non-compliant when judged
       against the Private Parking Single Code of Practice (PPSCoP) and
       broader consumer protection principles. While it may quote the
       statutory wording required by Paragraph 9(2)(f), it also
       prominently demands payment “within 28 days of the date issued”,
       which contradicts both PoFA’s own deemed service rule (the day
       after two working days later) and Section 8.1.2(e) of the
       PPSCoP, which requires that motorists be given a minimum of 28
       days from the date of receipt. This inconsistency introduces
       ambiguity as to the true deadline for payment and the point at
       which liability may be transferred to the Keeper.
       Such ambiguity undermines transparency, breaches the PPSCoP, and
       renders the notice misleading in a manner likely to disadvantage
       or confuse the average consumer. Therefore, the notice should
       not be relied upon to establish keeper liability.
       *****************************************************
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