Transcript Slide 1
The organisers of the Conference thank the following for their support Conference Sponsor www.buse.de Conference Supporter Academic Forum Sponsor Consiglio Nazionale dei Dottori Commercialisti e degli Esperti Contabili www.cndcec.it www.edwincoe.com The Improved Protection of Debtors in South-Africa: the Interaction between the New National Credit Act and the Insolvency Act Professor Leonie Stander, North-West University, South Africa • Objective of NCA: • Debt-relief to over-burdened consumers • Purpose of NCA: • Promote responsibility • Encouraging responsible borrowing • Avoidance of over-indebtedness • Fulfilment of financial obligations • Discourage reckless credit • Aims of NCA: – Address + prevent over-indebtedness – Provides mechanisms – Resolving over-indebtedness – S 3(g) formulates core principle: • Satisfaction by consumer • Of all responsible financial obligations – Clear: Does not afford discharge • Same manner as IA Relevant: 3 procedures • S 85 – 88 (court + consumer) – Provides for alleviation of over-indebtedness through process of debt relief • S 81 – 84 – Concerns reckless credit; prevention + remedies thereof • S 129 – 133 (credit provider) – Deal with debt enforcement • Over-indebtedness (s 79) – Debt-review + restructuring/re-arrangement plan – By agreement or court order • period of the agreement extended + • amount of each payment reduced • or payments due postponed during • specified period • Or combination of both • A 88(3): effect of debt review/re-arrangement plan – credit provider (creditor) – Not entitled to exercise or enforce – Rights or security under agreement – By means of litigation – Or any other judicial process • Reckless credit (s 80) – setting aside of debtor’s rights + obligations – Suspension of force + effect of agreement • Debt enforcement – S 129(1)(a): creditor obliged – written notice • propose that debtor refer the credit agreement to debt counsellor • proposing a debt repayment plan • If creditor agrees to the plan • debt enforcement procedure is stayed Questions: • While under debt review/subject to debt restructuring: – Will creditor be able to apply for compulsory sequestration? – Will such application amount to debt enforcement? – Will debtor be able to apply for voluntary surrender? • Should court refuse since debtor does not, in doing so, avail himself debt relief measures provided for by NCA? – Is the sequestration procedure • (as a collective debt settlement procedure; • Species of execution; • Equal treatment of creditors) – Ousted by the debt review procedure • (as a procedure for satisfaction of all responsible financial obligations by an over-indebted consumer) Point of departure: • Insolvency Act ousted? – S 2(7): provisions of NCA do not – Limit, alter, amend or repeal – Any provision of any other act – Except • when specifically set out in • or necessarily implied by NCA • No reference to IA in any section • Refer in Schedule 2 – To s 84 and amend – To include installment agreement – Conclusion? • Excluded by necessary implication? – NCA regulates “credit agreements” only – Unfair + unjustified as against ordinary creditor • To prevent him from sequestrating debtor • Because under debt review with regard to CA • To which creditor is not party • Application for voluntary surrender – Court has discretion to grant order – If satisfied that: • Insolvent • Formalities • Free residue • Advantage creditors • Advantage of creditors decisive role – Court will consider alternatives – Such as debt arrangement/restructuring – What is the best option/solution? • Ex parte Ford 2009 (3) SA 376 (WCC) – Major portion of liabilities: credit agreements – Huge debts, small income – Indicates over-indebtedness, reckless credit – Court referred to its powers in s 85 – Information given insufficient – Decided in effect: • NCA more appropriate mechanism in circumstances • Thus: Necessary implication • before making application – Debtors must take into account – Options outside sequestration – Where debt largely consists of CA’s – Remedies provided by NCA • Compulsory sequestration – Court has discretion to grant order – If satisfied that: • Applicant is creditor • Debtor insolvent/act of insolvency • Formalities • Reason to believe: Advantage creditors • Again advantage of creditors decisive – Other alternatives also relevant – Same factors as in Ford-decision • Other scenario: – Investec Bank v Mutemeri 2010 (1) SA 265 (GSJ) • Debtor applied for debt review • Would be heard one year later – 2 Questions: 20 • Is s 88(3) applicable? – (when notice of debtor's application for debt review received – creditor may not exercise/enforce any right under CA) • No, creditor may rely on claim ito CA to qualify as creditor to apply for sequestration • It does not exercise/enforce its rights in doing so • Is application for seq “order to enforce credit agreement” ito s 130? – Then notice ito s 129 essential • Court: not ordinary debt enforcement – “The purpose or effect of the sequestration is merely to bring about a convergence of claims against an insolvent estate to ensure that it is properly wound up in an orderly fashion and that the creditors are treated equally.” • S 29 notice not necessary • Crux: estate of debtor subject to debt review may be sequestrated • Naidoo v ABSA Bank Ltd 2010 (4) SA 597 (SCA) – Debtor sequestrated – Appealed: creditor did not give notice ito s 129 23 – Although not debt enforcement – S 130(3): “any proceedings …in respect of a credit agreement” – Decision: • Seq of debtor's estate not an order for enforcement of sequestrating creditor's claim, but species of execution • S 130(3) must be read in context • Observations The organisers of the Conference thank the following for their support Conference Sponsor www.buse.de Conference Supporter Academic Forum Sponsor Consiglio Nazionale dei Dottori Commercialisti e degli Esperti Contabili www.cndcec.it www.edwincoe.com The organisers of the Conference thank the following for their support Conference Sponsor www.buse.de Conference Supporter Academic Forum Sponsor Consiglio Nazionale dei Dottori Commercialisti e degli Esperti Contabili www.cndcec.it www.edwincoe.com The organisers of the Conference thank the following for their support Conference Sponsor www.buse.de Conference Supporter Academic Forum Sponsor Consiglio Nazionale dei Dottori Commercialisti e degli Esperti Contabili www.cndcec.it www.edwincoe.com The organisers of the Conference thank the following for their support Conference Sponsor www.buse.de Conference Supporter Academic Forum Sponsor Consiglio Nazionale dei Dottori Commercialisti e degli Esperti Contabili www.cndcec.it www.edwincoe.com