It's an N150 There is a whole section on settlement. Do I want to try and settle the claim before the hearing? Do I want a 1 month stay ? (I think I do) Have I attached a list of directions? (I don't know if I need to?) Have I made any applications in this claim? (I don't know if I have?) In the other info box I want to add that I want the 1 month stay as I have not have the chance to apply through the proper means for a PPI refund with the relevant questionaire, and then if necessary the fos. Is that how a stay could be used? They have denied all liability to my PPI reclaim (I don't know how an external solicitor can do that without investigating, and they are allowed to deny without giving any reasons or evidence) and my reclaim if charges. Bit stuck and struggling to find a good online guide/ explanation to the sections Thanks

Hi Please can someone point in the right direction for how to complete an allocation questionnaire? My defence and counterclaim are related to PPI mis selling and unfair charges Will mediation help me? What would be involved in this? Would this help me explain how my PPI was mis-sold as I have not yet had the opportunity to complete a PPI questionnaire and apply for a refund. What does a 1 month stay mean and would this be a good thing? I only have two days left to fill this in and I have no idea what to do Thanks

Called the court today for an update. I thought that the pt 20 defendant had only 14 days plus service to submit a defence. Court says no pt 20 defence received, and are not legally trained to advise whether time is up for welcome or if they have longer to reply. Is it a strict 14 days, or could it be that the court would be lenient with them? Or is it 28 days? All I have had is a change of solicitor letter, and a letter of proposed allocation to SCT. Thanks

So defend all and pay if necessary is better than admitting and paying right now. Thanks

If I defend all, and it turns out I still owe them, I won't get in extra trouble will I? I owe them a wee bit. They owe me a truck load in PPI. So they owe me. Sorry for panic, I have to take this to court this arvo

Hi, I need some very urgent help. My defence, pt 20 and payment has been returned as I needed to submit everything with form n9b. Do I Dispute the full amount?

Just so I know what to expect, does claimant/pt 20 def have 14 days to defend the cc? Then does the judge decide what happens next? I guess I will have to stump up more cash for the next steps too? Hope it's worth it!

Ok excellent, off to the post office then! Thanks so much

Hi Andy yes I will remove that when I finalise my document. I have it in word so will do that when I format it and add my personal details. Is everything else ok? When I send, do I also include all my calculations for the cc parts? I send a copy each to court and claimant?

Andy, hope this is looking ok now....? 1.The Claimant claims for arrears sums due under a fixed sum loan agreement regulated by the consumer credit act 1974 entered into between the Claimant and the Defendant on xx/xx/xxxx The Defendant admits that in or about XX/XXX/XXXX she entered into an agreement with the Claimant and which was an agreement regulated by The Consumer Credit Act 1974 (The Act), which was a refinance of loan xxxxxxxx, which was a refinance of loan xxxxxx. 2.The Defendant failed to pay the contractual installments on time in compliance with the terms of the agreement The Defendant admits failure to meet the contractual installements due to a change in employment circumstances. The Defendant was under the impression that the PPI would cover payments in such circumstances where the purchaser of the PPI (the Defendant) was unable to meet payments. The PPI did not cover the Defendant’s circumstances, and, aside from inflating the loan to unaffordable proportions, was mis-sold and useless to the Defendant. 3.The arrears balance of the unpaid contractual installments as of xx/xx/11 amounts to £xxxxx The amount the Claimant claims to be entitled to does not take into account all the payments made by the Defendant to the account. The Claimant's claim has neglected to take account of the Defendant's payments totalling £2569.26. 4.The term of the agreement expired on xx/xx/09 The Defendant neither confirms nor denies that the loan agreement expired on xx/xx/09. No such notification has been received from the Claimant, and all terms of the agreement provided by the Claimant are illegible. 5.The Claimant complied with section III and IV and annex B of the PD pre-action conduct by sending the Defendant a letter before action on xx/xx/13 to which the Defendant failed to respond It is denied that the Claimant complied with the pre-action conduct. The Defendant did not the noted letter before action on xx/xx/13. The only copies received by the Defendant are those attached to the particulars of claim dated xx/xx/xx. Furthermore, the Claimant stated they would start legal proceedings on xx/xx/xx, when in fact they started legal proceedings on xx/xx/xx (this is -1 day from the date they stated.) The Claimant claims: 6. Fixed sum loan agreement arrears of £xxxxxx The amount detailed in the Claimant’s claim includes the Claimant's 'ad hoc' fees which the Defendant assumes to be administration fees, late payment charges and like provisions, in which case the Claimant's charges bear no relation to the action taken. When asked to provide the actual cost of said 'ad hoc' actions by way of a Subject Access Request, the Claimant negated to provide such information. * The amount detailed in the Claimant's claim includes mis-sold PPI added to the loan account xxxxxx. The loan paperwork was signed in a closed room with just the Claimant's salesperson and the Defendant present. The PPI was a strict condition of being accepted for the finance. In no way did the Claimant's salesperson make it clear that the PPI was optional, and/or that could be purchased elsewhere if necessary. The amount detailed in the Claimant's claim includes mis-sold additional insurances, and they were added by the Claimant without consulting the Defendant. As an example the Claimant added 'Homecare 24’, to the Defendant's loan which would ‘help immediately in case of a household emergency such as roof damage or plumbing problems’. The Claimant knew the Defendant was not a homeowner, was renting a room in a house, and that such problems would be the responsibly of the Defendant's landlord. The Defendant was already paying for insurance to protect their possessions for such events from another insurer, and had the Defendant been asked whether she wanted to take extra insurance, the Defendant would have declined. For all insurances added, had the Defendant been asked whether she wanted to purchase ANY extra insurance, the Defendant would have declined to take any. * The amount detailed in the Claimant's claim includes the unpaid portion of the mis-sold PPI other insurances added to the loan account xxxxxx. 7. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief. Now start your Part 20 Counter Claim here * * * Part 20 Counter Claim 1.**** The Defendant/PT 20 Claimant claims sums paid to the Claimant/PT 20 Defendant in relation to unfair ‘ad hoc fees’ incorporated within the sum demanded by the Claimant/PT 20 Defendant, which are sums claimed for administration fees, late payment charges and like provisions. These are disproportionate to the action which they relate to. When asked to provide the actual cost of said 'ad hoc' actions by way of a Subject Access Request, the Claimant/PT 20 Defendant did not provide such information. * 2.**** The Defendant/PT 20 Claimant claims sums paid to Claimant/PT 20 Defendant for loan agreement xxxxxx in relation to mis-sold PPI and other insurances within the sum demanded by the Claimant/PT 20 Defendant. The Defendant/PT 20 Claimant did not choose PPI; the salesperson insisted it was included in the loan and that the loan would not be possible without it. Furthermore, when the insurance was needed to help cover payments, the PPI failed to cover the payments as the sales representative had described they would. The loan paperwork was signed in a closed room with just the Claimant/PT 20 Defendant's salesperson and the Defendant/PT 20 Claimant present. In no way did the Claimant/PT 20 Defendant's salesperson make it clear that the PPI was optional, and/or that could be purchased elsewhere if necessary. * 3.**** Loan agreement xxxxxx was a refinance of an older loan agreement xxxxxxxx within which the Defendant/PT 20 Claimant was also mis-sold PPI as per the circumstances described in paragraph 2. The Defendant/PT 20 Claimant did not choose PPI, but the salesperson insisted it was included in the loan and that the loan would not be possible without it. * 4.**** Loan agreement xxxxxx was a refinance of an older loan agreement xxxxxxxx within which the Defendant/PT 20 Claimant was also mis-sold PPI as per the circumstances described in paragraph 2. The Defendant/PT 20 Claimant did not choose PPI, but the salesperson insisted the loan would not be possible without it.* * 5.**** It is not clear from the paperwork provided by the Claimant/PT 20 Defendant what, if any, PPI rebate was calculated and refunded when the two loan refinances, as noted in paragraphs 3 and 4 above, took place. * 6.**** The Defendant/PT 20 Claimant requests removal of the unpaid portion of PPI and other insurances included within the sum the Claimant/PT 20 Defendant claims to be entitled to. * And the Defendant/PT 20 Claimant claims: * a)**** The sum of £303.23 for unfair charges plus compound interest of £109.24 at 42.6% APR to 01/03/2008 plus 8% interest of £176.41 to date of claim. * b)**** PPI (and other insurances) reclaim for agreement xxxxxx totalling £1626.44 plus 8% interest of £519.97 to date of claim. * c)**** PPI (and other insurances) reclaim for agreement xxxxxx totalling £701.68 plus 8% interest of £458.96 to date of claim. * d)**** PPI (and other insurances) reclaim for agreement xxxxxx totalling £219.97 plus 8% interest of £161.03 to date of claim. * e)**** PPI and insurance rebate with reference to the two loan refinances as above, or calculations to prove otherwise. * f)***** Removal of the unpaid portion of PPI and insurances included within the sum the Claimant/PT 20 Defendant claims to be entitled to. The Defendant/PT 20 Claimant, to the best of her ability, estimates this sum to be £1503.46, and, as such, would like to ask the court to make the calculation with a greater degree of accuracy. * g)**** Interest pursuant to Section 69 of the County Courts act 1984 at the rate of 8% per annum until judgement or payment. * h)**** Costs in the case (Small Claims Track). Statement of Truth I, the Defendant/PT 20 Claimant believe that the facts stated in this Defence and Counter claim are true. Dated xxxxxx

Right ok. I'll scrub the bit about notice of assignment then. Although had I received any letter before action from a random company I would not have believed it. Maybe that's the effect they wanted when they send out bulk letters. Hopefully Andy or someone will help me with the final stages of my defence

So how does this affect people in our circumstances? I have thought it a bit odd that I had been paying a company other than WF. Does it affect defence and claims?

Welcome I think. Will confirm when I get home tonight. How does that change things?

Hope this is looking ok now....? 1.The Claimant claims for arrears sums due under a fixed sum loan agreement regulated by the consumer credit act 1974 entered into between the Claimant and the Defendant on xx/xx/xxxx The Defendant admits that in or about XX/XXX/XXXX she entered into an agreement with the Claimant and which was an agreement regulated by The Consumer Credit Act 1974 (The Act), which was a refinance of loan xxxxxxxx, which was a refinance of loan xxxxxx. 2.The Defendant failed to pay the contractual installments on time in compliance with the terms of the agreement The Defendant admits failure to meet the contractual installements due to a change in employment circumstances. The Defendant was under the impression that the PPI would cover payments in such circumstances where the purchaser of the PPI (the Defendant) was unable to meet payments. The PPI did not cover the Defendant’s circumstances, and, aside from inflating the loan to unaffordable proportions, was mis-sold and useless to the Defendant. 3.The arrears balance of the unpaid contractual installments as of xx/xx/11 amounts to £xxxxx The amount the Claimant claims to be entitled to does not take into account all the payments made by the Defendant to the account. The Claimant's claim has neglected to take account of the Defendant's payments totalling £2569.26. 4.The term of the agreement expired on xx/xx/09 The Defendant neither confirms nor denies that the loan agreement expired on xx/xx/09. No such notification has been received from the Claimant, and all terms of the agreement provided by the Claimant are illegible. 5.The Claimant complied with section III and IV and annex B of the PD pre-action conduct by sending the Defendant a letter before action on xx/xx/13 to which the Defendant failed to respond It is denied that the Claimant complied with the pre-action conduct. The Defendant did not receive neither a notice of assignment from the Claimant, nor the noted letter before action on xx/xx/13. The only copies received by the Defendant are those attached to the particulars of claim dated xx/xx/xx. Furthermore, the Claimant stated they would start legal proceedings on xx/xx/xx, when in fact they started legal proceedings on xx/xx/xx (this is -1 day from the date they stated.) The Claimant claims: 6. Fixed sum loan agreement arrears of £xxxxxx The amount detailed in the Claimant’s claim includes the Claimant's 'ad hoc' fees which the Defendant assumes to be administration fees, late payment charges and like provisions, in which case the Claimant's charges bear no relation to the action taken. When asked to provide the actual cost of said 'ad hoc' actions by way of a Subject Access Request, the Claimant negated to provide such information. * The amount detailed in the Claimant's claim includes mis-sold PPI added to the loan account xxxxxx. The loan paperwork was signed in a closed room with just the Claimant's salesperson and the Defendant present. The PPI was a strict condition of being accepted for the finance. In no way did the Claimant's salesperson make it clear that the PPI was optional, and/or that could be purchased elsewhere if necessary. The amount detailed in the Claimant's claim includes mis-sold additional insurances, and they were added by the Claimant without consulting the Defendant. As an example the Claimant added 'Homecare 24’, to the Defendant's loan which would ‘help immediately in case of a household emergency such as roof damage or plumbing problems’. The Claimant knew the Defendant was not a homeowner, was renting a room in a house, and that such problems would be the responsibly of the Defendant's landlord. The Defendant was already paying for insurance to protect their possessions for such events from another insurer, and had the Defendant been asked whether she wanted to take extra insurance, the Defendant would have declined. For all insurances added, had the Defendant been asked whether she wanted to purchase ANY extra insurance, the Defendant would have declined to take any. * The amount detailed in the Claimant's claim includes the unpaid portion of the mis-sold PPI other insurances added to the loan account xxxxxx. 7. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief. Now start your Part 20 Counter Claim here * * * Part 20 Counter Claim 1.**** The Defendant/PT 20 Claimant claims sums paid to the Claimant/PT 20 Defendant in relation to unfair ‘ad hoc fees’ incorporated within the sum demanded by the Claimant/PT 20 Defendant, which are sums claimed for administration fees, late payment charges and like provisions. These are disproportionate to the action which they relate to. When asked to provide the actual cost of said 'ad hoc' actions by way of a Subject Access Request, the Claimant/PT 20 Defendant did not provide such information. * 2.**** The Defendant/PT 20 Claimant claims sums paid to Claimant/PT 20 Defendant for loan agreement xxxxxx in relation to mis-sold PPI and other insurances within the sum demanded by the Claimant/PT 20 Defendant. The Defendant/PT 20 Claimant did not choose PPI; the salesperson insisted it was included in the loan and that the loan would not be possible without it. Furthermore, when the insurance was needed to help cover payments, the PPI failed to cover the payments as the sales representative had described they would. The loan paperwork was signed in a closed room with just the Claimant/PT 20 Defendant's salesperson and the Defendant/PT 20 Claimant present. In no way did the Claimant/PT 20 Defendant's salesperson make it clear that the PPI was optional, and/or that could be purchased elsewhere if necessary. * 3.**** Loan agreement xxxxxx was a refinance of an older loan agreement xxxxxxxx within which the Defendant/PT 20 Claimant was also mis-sold PPI as per the circumstances described in paragraph 2. The Defendant/PT 20 Claimant did not choose PPI, but the salesperson insisted it was included in the loan and that the loan would not be possible without it. * 4.**** Loan agreement xxxxxx was a refinance of an older loan agreement xxxxxxxx within which the Defendant/PT 20 Claimant was also mis-sold PPI as per the circumstances described in paragraph 2. The Defendant/PT 20 Claimant did not choose PPI, but the salesperson insisted the loan would not be possible without it.* * 5.**** It is not clear from the paperwork provided by the Claimant/PT 20 Defendant what, if any, PPI rebate was calculated and refunded when the two loan refinances, as noted in paragraphs 3 and 4 above, took place. * 6.**** The Defendant/PT 20 Claimant requests removal of the unpaid portion of PPI and other insurances included within the sum the Claimant/PT 20 Defendant claims to be entitled to. * And the Defendant/PT 20 Claimant claims: * a)**** The sum of £303.23 for unfair charges plus compound interest of £109.24 at 42.6% APR to 01/03/2008 plus 8% interest of £176.41 to date of claim. * b)**** PPI (and other insurances) reclaim for agreement xxxxxx totalling £1626.44 plus 8% interest of £519.97 to date of claim. * c)**** PPI (and other insurances) reclaim for agreement xxxxxx totalling £701.68 plus 8% interest of £458.96 to date of claim. * d)**** PPI (and other insurances) reclaim for agreement xxxxxx totalling £219.97 plus 8% interest of £161.03 to date of claim. * e)**** PPI and insurance rebate with reference to the two loan refinances as above, or calculations to prove otherwise. * f)***** Removal of the unpaid portion of PPI and insurances included within the sum the Claimant/PT 20 Defendant claims to be entitled to. The Defendant/PT 20 Claimant, to the best of her ability, estimates this sum to be £1503.46, and, as such, would like to ask the court to make the calculation with a greater degree of accuracy. * g)**** Interest pursuant to Section 69 of the County Courts act 1984 at the rate of 8% per annum until judgement or payment. * h)**** Costs in the case (Small Claims Track). Statement of Truth I, the Defendant/PT 20 Claimant believe that the facts stated in this Defence and Counter claim are true. Dated xxxxxx

Thank you Just picking up on your comments above 2. Reason for failing to meet payments...can I say that loan became unaffordable due to change in employment circumstance that PPI would not cover. 4. Term of agreement expiry date. I think that date is the 36 months ie the duration of the loan. The default notice I got a copy of (no original received) defaults me about 2.5 years after the date the agreement expired. Confused! 5. I received a copy of lba with their particulars. Didn't get the original. The date they say they would start legal action is the day after they actually did though. They left it 13 not 14 days I think. Didn't get original so not sure worth arguing. Will work on my part 20 again now Thanks

Andy, I have added my defence in red below each of their particulars. Is this what you mean? There are points I have no idea how to answer (where I have put ??) I'm still very confused about what I am doing. Is there a guide anywhere you could refer me to? So just to be clear, I need to go through each of their points, and answer them, before starting my CC pt 20 1.The claimant claims for arrears sums due under a fixed sum loan agreement regulated by the consumer credit act 1974 entered into between the claimant and the defendant on xx/xx/xxxx The Defendant admits that in or about XX/XXX/XXXX (he/she) entered into an agreement with the Claimant and which was an agreement regulated by The Consumer Credit Act 1974 (The Act). 2.The defendant failed to pay the contactual installments on time in compliance with the terms of the agreement This is correct – do I admit this? 3.The arrears balance of the unpaid contractual installments as of xx/xx/11 amounts to £xxxxx The amount the Claimant claims to be entitled to does not take into account all the payments made by the Defendant to the account. The Claimant's claim has neglected to take account of the Defendant's payments totalling £2569.26. 4.The term of the agreement expired on xx/xx/09 No idea what to add here 5.The claimant complied with section III and IV and annex B of the PD pre-action conduct by sending the defendant a letter before action on xx/xx/13 to which the defendant failed to respond I don't know if they did? I received no default or LBA The claimant claims: 6. Fixed sum loan agreement arrears of £xxxxxx The amount detailed in the Claimant’s claim includes the Claimant's 'ad hoc' fees which the Defendant assumes are administration fees, late payment charges and like provisions, in which case the Claimant's charges bear no relation to the action taken. When asked to provide the actual cost of said 'ad hoc' actions by way of a Subject access request, the Claimant did not provide such information. The amount detailed in the Claimant's claim includes the remainder of the PPI and other insurances added to the loan account xxxxxx. The loan paperwork was signed in a closed room with just the Claimant's employee and the Defendant present. The PPI was a condition of being accepted for the finance. No PPI, no loan. In no way did the Claimant's employee make it clear that the PPI was optional in the Defendant's circumstances, and/or could be purchased elsewhere as necessary. The defendant did not ask for the additional insurances and they were added by the Claimant. To underline this, the Claimant added 'Homecare 24’, to the Defendant's loan which would ‘help immediately in case of a household emergency such as roof damage or plumbing problems’. The Claimant knew the Defendant was not a homeowner, and was renting a room in a house and such problems would be the responsibly of the Defendant's landlord. The Defendant was already paying for contents insurance to protect their possessions for such events, and had the Defendant been asked whether he/she wanted to take extra insurances, the Defendant would have declined. 7. interest under s69 of the county courtact 1984 at the rate of 8% a year from xx/xx/11 to xx/xx/12 of £xxx ?? 8. Interest at the same rate up to the date of judgment or earlier payment at a daily rate of £1 ?? 9.Costs ??

The claimant claims for arrears sums due under a fixed sum loan agreement regulated by the consumer credit act 1974 entered into between the claimant and the defendant on xx/xx/xxxx The defendant failed to pay the contactual installments on time in compliance with the terms of the agreement The arrears balance of the unpaid contractual installments as of xx/xx/11 amounts to £xxxxx The term of the agreement expired on xx/xx/09 The claimant complied with section III and IV and annex B of the PD pre-action conduct by sending the defendant a letter before action on xx/xx/13 to which the defendant failed to respond The claimant claims: 1. Fixed sum loan agreement arrears of £xxxxxx 2. interest under s69 of the county courtact 1984 at the rate of 8% a year from xx/xx/11 to xx/xx/12 of £xxx 3. Interest at the same rate up to the date of judgment or earlier payment at a daily rate of £1 4.Costs

Thanks Andy, would be great if you could take a look today. Just re-read the POC and it is clear I have only answered the first one; but I have no idea how to answer the rest. If you could help that would be brilliant Also if the account was terminated in 09, is that when a default should have been issued. Does that mean a dn is irrelevant in this case?

Andy, please take a look at my first draft I've probably got a bit muddled with the two sections I have a couple of questions 1. Am I supposed to answer each of their particulars individually? 2. On the form N9B, do I defend all, or do I need to admit the part I still owe? I technically owe them £2k ish without netting off the PPI and charges But they owe me £4.2k as per my cc below, so overall they owe me £3.5k ish Thanks Defence 1. The Defendant admits that in or about XX/XXX/XXXX (he/she) entered into an agreement with the Claimant and which was an agreement regulated by The Consumer Credit Act 1974 (The Act). 2. The amount the Claimant claims to be entitled to does not take into account all the payments made by the Defendant to the account. The Claimant's claim has neglected to take account of the Defendant's payments totalling £2569.26. 3. The amount detailed in the Claimant’s claim includes the Claimant's 'ad hoc' fees which the Defendant assumes are administration fees, late payment charges and like provisions, in which case the Claimant's charges bear no relation to the action taken. When asked to provide the actual cost of said 'ad hoc' actions by way of a Subject Access Request, the Claimant did not provide such information. 4. The amount detailed in the Claimant's claim includes the remainder of the PPI and other insurances added to the loan account xxxxxx. The loan paperwork was signed in a closed room with just the Claimant's employee and the Defendant present. The PPI was a condition of being accepted for the finance. No PPI, no loan. In no way did the Claimant's employee make it clear that the PPI was optional in the Defendant's circumstances, and/or could be purchased elsewhere as necessary. 5. The defendant did not ask for the additional insurances and they were added by the Claimant. To underline this, the Claimant added 'Homecare 24’, to the Defendant's loan which would ‘help immediately in case of a household emergency such as roof damage or plumbing problems’. The Claimant knew the Defendant was not a homeowner, and was renting a room in a house and such problems would be the responsibly of the Defendant's landlord. The Defendant was already paying for contents insurance to protect their possessions for such events, and had the Defendant been asked whether he/she wanted to take extra insurances, the Defendant would have declined. 6. The amount of PPI and insurances included within the sum the Claimant claims to be entitled to can be estimated as follows: Original loan £7810.92 Loan without PPI £4681.02 Total PPI cost £3129.90 Total payments towards PPI £1626.44 PPI & insurances outstanding in loan £1503.46 The defendant cannot determine an exact figure for the remaining mis-sold PPI contained within the Claimant's claim, so would like to ask the court to make the calculation with a greater degree of accuracy. 7. It is denied that Welcome Finance served a default notice upon the Defendant. 8. In the circumstances the facts and matters set out in the Particulars of Claim do not give rise to an entitlement to claim any of the relief now sought by the Claimant. The Claimant’s claim to be entitled to £(total), to interest or to any other sum is denied. I'm not sure whether I need this / or how it should be phrased Part 20 counter claim The Defendant/Part 20 Claimant claims sums paid to the Claimant/part 20 Defendant in relation to unfair charges incorporated within the sum demanded by the Claimant which are sums claimed for their administration fees, late payment charges and like provisions, and are wholly disproportionate to the action which they relate to. The Defendant/Part 20 claimant claims sums paid to claimant/part 20 defendant for loan agreement xxxxxx in relation to mis-sold PPI and other insurances within the sum demanded by the Claimant. The defendant did not choose PPI, but the salesperson insisted the loan would not be possible without it. Loan agreement xxxxxx was a refinance of an older loan agreement xxxxxxxx within which the defendant was also mis-sold PPI. The defendant did not choose PPI, but the salesperson insisted the loan would not be possible without it. Loan agreement xxxxxx was a refinance of an older loan agreement xxxxxxxx within which the defendant was also mis-sold PPI. The defendant did not choose PPI, but the salesperson insisted the loan would not be possible without it. It is not clear from the paperwork provided by the Claimant/part 20 Defendant what PPI rebate was calculated and refunded when the above two loan refinances took place. And the defendant/Part 20 Claimant claims: (a) the sum of £303.23 for unfair charges plus compound interest of £109.24 at 42.6% APR to 01/03/2008 plus 8% interest of £176.41 to date of claim (b) PPI reclaim for agreement xxxxxx totalling £1626.44 plus 8% interest of £519.97 to date of claim © PPI reclaim for agreement xxxxxx totalling £701.68 plus 8% interest of £458.96 to date of claim (d) PPI reclaim for agreement xxxxxx totalling £219.97 plus 8% interest of £161.03 to date of claim (e) Interest pursuant to Section 69 of the County Courts act 1984 at the rate of 8% per annum until judgement or payment. (f) Costs in the case (Fast Track) Statement of Truth I, the Defendant/PT 20 Claimant believe that the facts stated in this Defence and Counter claim are true. Dated xxxxxx

Bingo! Thanks very much dx My spreadsheet is now complete so I can start writing my defence for the form Hope everything I have is correct I'll include all my calculations with my submission so I think my summary sheet will also be useful Thank you

Before I start writing I thought I would get all my figures in one place to work from I know we have been round this already but I just can't come up with the right figure to minus off the arrears that represents the remaining part of the PPI. My brain just can't do the maths So we have worked out that the total loan amount without PPI was £4681 And payments made to date are £5346 (£2935 total pre-action) I have the loan behavior link on the Guardian website, but I don't know how to apply that info to what I need to work out. Spent all evening on this and going round in circles Thanks (CC1 is scenario 1 – PPI reclaim for just one loan) (CC2 is scenario 2 – PPI reclaim for loan 1 + 2 +3) Not sure which to go for yet

Sorry postggj you have lost me. Is that with respect to the un-en cca? I was going to ask whether that should be something that goes in my defence? Also, not sure if these points are relevant ... I didn't receive a default notice but I got sent a copy and all the charges are contained within the sum owing I didn't receive the letter before action but again I got a copy in the POC, and the action was taken on the day before the letter says it was. Not sure if relevant. As far as I can see there is no mention of a default or this agreement on my credit files either. I don't want to draw attention to this though as that is good news for my cr. Thanks for the maths help dx This weekend is dedicated to getting my defence and cc drafted in full for review Thanks

Thanks dx I am still at a loss as to how to state on my counter claim how much I actually owe Would it be £4681 - (£130 x number of payments I made) I am guessing if I am counterclaiming it needs to be a) correct and b) a specific amount Thanks

Let me know if you need me to summarise, it's a pretty long thread now!

This is a personal WF loan