By Anthony J Cordato © Copyright Sydney 2009
Contents
This article has been prepared to provide a detailed introduction to how vendor finance has come to be used for the sale and purchase of real estate in Australia.
In this introduction, insights will be provided into how vendor finance currently ‘works’ and how it has developed in Australia.
It is an introduction which is intended to provide a general guide. It is not intended to be relied upon as a template for carrying out transactions. Professional advice needs to be obtained before using vendor finance for a real estate transaction.
These topics are covered:
- What is Vendor Finance?
- Why Vendor Finance is used for selling Real Estate
- A Century of use for the sale of Real Estate in Australia
- The three kinds of Vendor Finance
- Illustrations of Vendor Finance
- Vendor Finance as an investment method
- Documentation for Vendor Finance
Information upon Legislation which applies to Vendor Finance for Real Estate in Australia and the Tax Treatment of Vendor Finance are to be found under separate tabs in this website.
What is Vendor Finance?
Vendor Finance (also known as
‘seller finance’) is finance
offered by a seller (a Vendor)
to finance the sale of real
estate to a buyer (a Purchaser).
Sellers offer vendor finance to
a Purchaser to help a Purchaser
to purchase a home. Instead of
the Bank financing the
purchaser, the seller finances
the purchaser along the same
lines as a bank finances the
purchaser. With vendor finance,
instead of the purchaser making
weekly, fortnightly or monthly
payments under a mortgage to the
Bank, the purchaser makes these
payments under the vendor
finance to the seller.
In its simplest form, a Vendor
Finance transaction is
structured in this way - the
purchaser pays a deposit, then
makes regular payments over a
period of up to 30 years. It is
the fact that regular payments
are made to the Vendor to pay
the price, rather than the
payment of a lump sum to the
Vendor that makes the
arrangement a Vendor Finance
arrangement, as opposed to a
standard sale.
Vendor Finance is the first step
along the path to home
ownership. Sellers who offer
Vendor Finance offer purchasers
the opportunity to build up
sufficient equity (a deposit)
and a good track record of
payments (creditworthiness) to
qualify for bank finance at a
future time. Usually, after 2
years, and rarely more than 5
years, the purchaser has
sufficient equity and a good
track record to refinance with a
Bank.
Sellers who offer Vendor Finance
receive the price they want for
the property because they are
not selling on the basis of
price, they are selling because
the payment terms are attractive
to the purchaser. They are the
opposite of sellers who discount
the price for a sale.
In short, by using Vendor
Finance, the seller receives two
benefits: the first is that the
seller sells the property more
quickly than if offered at a
fixed price because the property
is attractive to more buyers;
and the second is the price does
not need to be discounted for a
quick sale, because payment
terms are being offered.
Vendor Finance is often referred
to as alternative housing
finance. It encompasses
instalment sales, rent to own
and sales with a carry back
mortgage finance.
Why
Vendor Finance is used for
selling Real
Estate
Saving the money to pay the
price to purchase real estate
without borrowing has been
uncommon since the 1950s because
of the high price of real estate
would mean saving for many
years, at the same time watching
the price rise, adding more
years to saving time.
The high price of real estate
leaves purchasers these days
with little choice but to borrow
money to purchase real estate.
The problem is – where can a
purchaser turn if they can’t
raise finance from a Bank or
Non-Bank lender?
The answer is vendor finance!
Here are some advantages
and disadvantages of
Vendor Finance:
The advantage of Vendor
Finance for both Vendors and
Purchasers of real estate are
that the sale is not dependent
on the Purchaser qualifying for
external finance from a Bank or
Non-Bank lender.
The advantage of Vendor
Finance for Purchasers - because
borrowing money is necessary for
purchasing real estate,
obtaining Vendor Finance from
sellers of real estate is a very
attractive proposition for
Purchasers as opposed to
qualifying for Bank Finance,
because Vendor Financiers will
finance where Banks cannot or
will not.
The advantage of Vendor
Finance for Vendors in providing
Vendor Finance is that the
Vendor secures a sale, at their
desired price.
The disadvantage for Vendors
in providing Vendor Finance is
that it ties the Vendor to the
property, potentially for some
time, and that the Vendor must
retain satisfactory security for
payment of the price.
The advantage for Purchasers
in using Vendor Finance is that
the Purchaser can purchase
immediately at an agreed price
rather than deferring purchase,
and receive the immediate
enjoyment of the property (i.e.
the Purchaser can move in).
The disadvantage for
Purchasers in using Vendor
Finance is that Purchaser cannot
sell or mortgage the property
without first making full
payment to the Vendor. Also, the
money the Purchaser pays may be
at risk if the Vendor defaults
under its mortgage over the
property.
This article will explain how
these advantages and
disadvantages are dealt with.
A
Century of use for the sale of
Real Estate in Australia
Vendor Finance for real estate
has a long history in Australia.
In the land boom years of the
1870s and 1880s, property
developers subdivided land and
sold the land to purchasers to
build homes upon the land and to property
speculators who purchased the
land for re-sale. Property
developers offered
terms
to sell the land, typically
¼ of the price as a deposit, ¼
after six months, ¼ after 12
months and ¼ after 18 months,
with interest payable at 6% p.a.
on the outstanding amounts.
By the early 1900s, the practice
was widely used and accepted,
with land in suburban locations
such as North Sydney and
Chatswood advertised for sale on
terms.
In 1927, the High Court of
Australia considered the tax
consequences of Vendor Finance,
in the case of:
The
Federal Commissioner of Taxation
-v- Thorogood.
The
facts:
James H Thorogood carried on the
business of buying land,
dividing it into allotments and
building houses on them, selling
these as house and land
packages.
In some sales, a deposit was
paid in cash with the balance
price payable by instalments
over several years. In these
sales, Thorogood “funded” the
whole price as seller finance.
These sales were documented by a
Contract for Sale, which
continued for several years,
with Thorogood retaining the
title to the property in his
name until the contract was
completed by payment of the
final instalment.
In other sales, the Purchaser
paid a deposit, paid a large
part of the price using external
finance secured by first
mortgage, with the balance of
the price funded by Thorogood,
taking as security a second
mortgage over the property.
These sales were documented by a
Contract for Sale which was
completed in the normal time.
Title to the property was
transferred immediately to the
Purchaser. The documentation for
the seller finance took the form
of a second mortgage in favour
of Thorogood which was
registered, ranking after a
first mortgage from an external
financier, to secure the balance
of the price owing to Thorogood.
In both cases, interest was
payable on the balance price
owing to Thorogood.
The
dispute:
The Federal Commissioner of
Taxation assessed Thorogood to
pay income tax on the whole
price in the year the Contract
for Sale was entered, even
though considerable portions of
the price were payable in future
years. Thorogood objected and
contended that he should pay tax
only on the portions of the
price that were actually
received in the tax year in
question.
The decision:
The High Court did not decide
the dispute - it decided only
that it was possible to take
either view of the tax
consequences of the transaction,
depending upon the facts (Report
found in: (1927) Volume 40
Commonwealth Law Reports at page
454).
For our purposes, the important
point is that the legality of
both forms of Vendor Finance was
accepted by the High Court.
For the current tax position,
see the tab on ‘Tax and Vendor
Finance’.
The use of Vendor Finance
fluctuates according to social
and economic conditions and the
availability of Bank and
Non-Bank finance.
- In the 1950’s and
1960’s, land for
housing was subdivided and
sold on Vendor Finance terms
of up to 5 years with
instalments paid monthly.
The reason Vendor Finance
was used was that the
banking system did not
provide loans for the
purchase of blocks of land
for housing.
- Therefore, in the 1950’s
and 1960’s, most young
couples looking to build a
home would purchase a block
of land to build a home
upon, from a property
developer “off the plan” in
a land subdivision, using
terms finance. Once the land
was paid for, they would
borrow the money to build
their home from a Bank.
- In the 1960’s, 1970’s &
early 1980’s, many young
couples would purchase house
and land packages from
builders, using terms
finance. In those times, a
Purchaser would need to
demonstrate a 12 months
savings record and have a
25% deposit to borrow from a
Bank (the Banks in those
days would
lend up to 75% of the value only).
Generally after one year,
the builder would “cash out”
the terms finance Contract,
by transferring the Contract
to their financier, who
might then provide normal
mortgage finance to the
Purchaser until the
purchaser was able to
refinance with a Bank.
- From the mid 1980’s to
date, the deregulation of
the banking system has
resulted in an increasing
availability of mortgage
finance from Banks and
non-Bank lenders (up to 95%
of valuation with minimal
savings record). As a
result, terms finance has
been used relatively rarely
for sales of property.
However, it is interesting
to note that it has been
used continuously for sales
by the NSW Department of
Housing to its tenants since
the early 1970’s, with 40
year terms on a 25% deposit
being common.
- Recently, there has been
a tightening of loan
approval conditions, and an
unsatisfied demand for
Vendor Finance has become
apparent. It is found
amongst purchasers with low
deposits, purchasers who
have their own business or
trades and purchasers whose
credit rating is impaired,
who do not qualify for Bank
or non-Bank Loans.
Vendor Finance is recognised officially by the Australian Government as a means to purchase a home. In the 2006 Australian Census, question 56 was -
Is this dwelling: Being purchased under a rent/buy scheme? 1.2% of Australians ticked “yes”.
The three forms of Vendor
Finance
The decision of
Thorogood describes two
kinds of Vendor Finance namely:
-
Instalment Sales Finance or
Terms Finance:
In this form of Vendor
Finance, the property is
sold at an agreed price, but
instead of the price being
paid up front where the
price is funded with Bank
finance, the Vendor agrees
to accept payment of the
whole of the price by
instalments, over a period
of time.
The key elements are that the Vendor fully funds the price by setting up an instalment payment arrangement or plan in the Contract; the Purchaser takes possession once the Contract is entered into; and the title (i.e. ownership) remains in the Vendor’s name until the final instalment is paid (or the loan is refinanced).
The Contract period is usually 20, 25 or 30 years, but generally the Purchaser will pay out the amount outstanding under the Contract as soon as they are able to refinance with external finance, which is usually between 2 to 5 years afterwards. The Purchaser pays interest at a rate of between .5% and 3% above the interest rate the Vendor is paying to their Bank on their loan.
The Vendor keeps their existing loan on the property. This form of vendor finance is sometimes referred to as a ‘wrap around mortgage’ because the Vendor gives the Purchaser a mortgage which is for a greater amount and is at a higher interest rate than their own mortgage. It is called a ‘wrap’ for short.
This form of Vendor Finance is documented by an Instalment Contract.
-
Mortgage Carry back Finance:
Traditionally, especially
for the sale of farming
properties, the Vendor loans
the greater part of the
price to the purchaser under
a mortgage back finance
arrangement. The Vendor
transfers the title to the
property to the Purchaser,
and takes a registered first
mortgage as security for the
balance price that is due
and owing. The Vendor is
said to carry back the price
that is not received on the
property transfer, and this
is therefore known as first
mortgage carry back finance.
First Mortgage carry back finance is what solicitors usually have in mind when the expression “vendor finance” is used because it is the form of Vendor Finance that is closest to their experience.
The way that mortgage carry back finance is used by vendor financiers these days is to finance the deposit, and for the Purchaser to obtain Bank finance for most of the price.
This form of Vendor Finance is known as second mortgage carry back finance or deposit finance, because the deposit is funded by the Vendor.
The key elements of second mortgage carry back finance are that an external financier funds most of the price The external financier takes a first mortgage security. The title to the property passes into the purchaser’s name immediately. The Vendor funds the shortfall between the price and the external finance (that shortfall is the unpaid price which is often 10% to 20%) and takes a second mortgage over the property as security for payment. Usually the Purchaser has a small cash deposit, and so the Vendor Finance is usually less than 20%. The Vendor Finance may also cover purchase and loan expenses, such as stamp duty.
There is a third form of vendor finance, as follows:
-
Rent to Buy (Lease Option)
Finance:
In this form of Vendor
Finance, the Vendor allows
the Purchaser to build up
the deposit, by paying extra
money, over and above paying
the rent on the property.
The way it works is that the Vendor rents the property to the Purchaser under a normal residential tenancy agreement. At the same time, the Purchaser pays more than the market rent, with the extra, credited towards the deposit payable if the purchaser decides to go ahead and purchase of the property. The right to purchase is contained in a separate document, called an option, in which the Vendor agrees to sell the property to the Purchaser for a fixed price.
This form of Vendor Finance is useful where the Purchaser is not sure whether or not they wish to purchase the property, it is a ‘try before you buy’ arrangement.
The right to purchase is found in an option to enter into a Contract for Sale, at an agreed price. There is an ‘up front’ payment, after which time, part of the rent payments or ongoing payments under the option are credited against the deposit payable under the Contract for Sale, if the purchaser takes the next steps and proceeds with the Contract for Sale. The Purchaser enters the Contract for Sale by ‘exercising’ the option, using the payments credited as the deposit. Until the option is exercised, the Purchaser rents the property under a Residential Tenancy Agreement.
Illustrations of Vendor Finance
These three simple illustrations
are of the three common forms of
Vendor Finance for a house. Assume a house
is to be sold for $250,000, and
is capable of being rented for
$240 per week.
Illustration 1 – an Instalment
Sale or Terms Sale
The house is sold with a deposit
payable of $10,000, and with the balance
price of $240,000 payable by
1,560 instalments of $425 per week
over the next 30 years. For this
example, the instalment amount
is comprised of both principal
and interest, and the interest
rate is assumed to be 8.5% per
annum. The Purchaser moves in
immediately, also paying $35 per
week to reimburse all rates and,
insurances. The Purchaser is
also responsible for
maintenance. This example is a
terms sale or an instalment
sales form of Vendor Finance
because the price payable under
the Contract is payable by
instalments.
Illustration 2 – Rent to Buy or
Rent to Own (Lease Option)
A Purchaser rents the house at
$260 per week for three years,
at the same time putting aside a
little extra ($125 per week)
which is paid to the Owner along
with the rent, making the total
payment $385 per week. Over 3
years, the ‘extra’ paid totals
$19,500, which together with an
up-front option fee paid of
$5,500, adds up to $25,000. The
$25,000 represents a deposit of
10% credited as paid towards the
price of $250,000. Therefore, at
the end of the three years the
Purchaser is in a position to
use external finance to pay the
balance price of $225,000, which
represents 90% of the price. If
the purchaser requires further
time, the option can be
extended.
This example is a rent to buy or
rent to own form of Vendor
Finance, documented as a lease
with an option.
Illustration 3 – mortgage carry
back
A Purchaser is given assistance
to pay up to a 20% deposit of
$50,000, by the Vendor giving
deposit finance, with the
balance funds (80% of the price)
loaned by an external financier.
The Purchaser pays interest only
of $76.92 per week on the
deposit finance, calculated at
8% per annum and repays it all
at the end of 3 or 5 years out
of savings or external
financing. This example is a
mortgage carry back form of
Vendor Finance, which in this
example is used to fund the
payment of the deposit. It is documented by a mortgage.
Vendor Finance as an investment
method
Advantages
Vendor Finance is gaining
popularity as an investment
method for investors because it
generates positive cashflow from
residential property.
‘Positive cashflow’ means that
the income from the property
exceeds the outgoings, be they
mortgage payments, rates and
taxes, maintenance and repairs.
It is the direct opposite of negative
gearing, which is where the
owner must contribute to the
shortfall in the money available
to meet the outgoings from their
own pocket.
Vendor Finance is successful as
an investment method because it
meets the demand by Australians
who want to purchase their own
home, to ‘escape’ from the
rental market, but who for some
reason are ‘locked out’ of the
banking system.
Specifically, the demand by
purchasers for Vendor Finance in
Australia is to be found in two
situations:
- Where the Purchaser has
little or no deposit or has
an insufficient savings
record.
- Where the Purchaser, is
not creditworthy and cannot
obtain bank or non-bank
finance. Some Purchasers may
be creditworthy, but find it
difficult to deal with
lenders. Other Purchasers
are not creditworthy. They
must repair a poor credit
rating, or have difficulty
proving income because they
are self employed or have
casual or irregular income
or have been in their
employment for less than one
year.
- Where the property is such that bank or non-bank finance is not easily obtained by anyone. Examples are vacant land (especially outside the Metropolitan Area), acreage, farms, commercial property and unusual property such as boarding houses. Many Banks will not lend on houses in towns with a population of less than 10,000.
Using the Instalment Sales
Finance or Terms Finance Method
for investing
Instalment Finance is a method
commonly used used by investors
to sell a residential property
to generate positive cashflow
from the property. The investor
purchases the property using
external finance, and then
privately finances a purchaser
to purchase the property, on
terms. This is known as “wrap
around” financing, commonly
known as “wrapping”. The term
‘wrap’ was coined by US and US
based investors, and has been
used extensively in Australia
since 1999.
The outstanding advantage for an
investor of using the “wrap”
method is that the investment
return from the property is
strongly cashflow positive from
day one. This is achieved by
setting a level of instalments
payable by the Purchaser which
is greater than the amount of
the investor’s payments to their
Bank. In addition, the investor
passes responsibility to the
Purchaser to pay the outgoings,
consisting of rates, taxes,
insurance premiums, and the
responsibility for repairs and
maintenance. Using this
technique, investors can achieve
returns on residential real
estate investment comparable to
the returns achieved on
commercial real estate
investment.
Using
the Rent to Buy Method for
investing
Rent to Buy is similar in terms
of objectives to “wrap”
financing, in that the objective
is to boost the cashflow return
from residential property. The
boost is in the form of the
payments made by the purchaser
over and above the normal rent.
Usually, the cashflow is not as
strong as the cashflow on a
“wrap”, because the Purchaser
has not committed themselves to
the property to the same extent
as they commit themself under a
“wrap”. Purchasers in a rent to
buy are equivocal; they are
thinking ‘rent now, purchase
later’ rather than ‘purchase
now’.
Refinancing by Purchasers of a
Vendor Finance arrangement
Whatever the form of
documentation is used, Vendor
Finance is a means to an end,
the end being the Purchaser
refinancing using external
finance. Vendor Finance is only
the “the first stepping stone on
the path to home ownership”.
Once the Purchaser has built up
equity in the property by home
improvements, savings or capital
appreciation, and has a track
record for payments, then the
Purchaser is able to refinance
the Vendor Finance on more
favourable terms (lower interest
rates for example).
Therefore although the
Instalment Sales documentation
is written for a term of 20, 25
or 30 years, in many cases a
Vendor Finance arrangement can
be for a term of as little as 1
to 2 years, and generally no
more than 2 to 5 years. This
reduces risks to both Vendor and
Purchaser appreciably.
The period of 2 to 3 years for
the Rent to Buy arrangement puts
a formal time frame upon the
Purchaser to purchase the
property. The Purchaser has a
deposit and a track record of
payments, to enable the
Purchaser to obtain external
finance, should the Purchaser
choose to proceed with the
purchase of the property. Should
the Purchaser decide not to
proceed, the Purchaser moves out
and the Vendor keeps the
payments.
Joint Ventures
Instalment Sales and Rent to Buy
have become popular in Australia
with Investors because of the
high returns achievable on money
invested. But often Investors do
not have the time or skill to
put Vendor Finance arrangements
into place.
Investors often utilise the
services of an experienced
“wrapper” as a co-investor under
a Joint Venture Agreement, to
put a Vendor Finance arrangement
into place.
A separate commentary upon Joint
Venture Arrangements appears on
a tab on this website.
Other investment methods
Other methods have been
developed in the USA for
property investment, such as
purchasing “subject to” an
existing mortgage (i.e. taking
over the property, subject to
the Vendor’s mortgage). These
methods are difficult to import
easily into Australia, because
they work in the absence of a
title registration system, in
contrast to the situation in
Australia, where a title
registration system exists. In
Australia, the process of taking
over a property, ‘subject to’
the existing mortgage is more
formal, but possible, using an
assumptive lease option
arrangement.
Tenancy in common arrangements,
where a vendor and purchaser
each take shares in a property
also come in and out of fashion
in Australia. This investment
method starts with an investor
who provides a deposit for the
purchaser to purchase a home,
and at the end of a specified
period, the purchaser must
refinance or sell to repay the
deposit. These tenancy in common
arrangements are far less
attractive to an investor than
other Vendor Finance techniques
and will not be examined
further.
There are a number of property
trading methods, generally using
options, which are also not
examined in this article.
Documentation for Vendor Finance
The Instalment Contract
Where Vendor Finance consists of terms payments or instalment payments then it is known as terms finance and the sales are called terms sales. Terms sales are documented by way of an Instalment Contract.
An Instalment Contract takes the form of a standard Contract for Sale of real estate which has been modified to provide for the payment of the price by instalments, over time.
These are the modifications required to be made to a standard Contract for Sale to convert it into an Instalment Contract:
- The price set represents
a profit over the purchase
price. The price is payable
by instalments, instead of a
lump sum on completion.
- The instalments are
payable regularly, either
weekly, fortnightly or
monthly, and will include
interest. The interest rate
is usually set at a premium
above the interest rate
payable on the investor’s
loan / mortgage upon the
property.
- The time between the
date the Contract is entered
and is therefore legally
binding (called “the
exchange of Contracts”) and
completion of the Contract
(also called “settlement” in
Australia and “closure” in
the USA) may be as long as
25 or 30 years, rather than
the 30 days, 42 days or up
to 90 days found
in a standard Contract.
- The Purchaser enters
into possession of the
property, under a licence
rather than a lease, and
will be responsible for all
expenses as from the
exchange of Contracts (i.e.
when the contracts are
signed and the deposit is
paid).
- During the continuation
of the Contract, the
Purchaser must reimburse the
Vendor for all Council and
Water rates, taxes and other
outgoings, the insurance
premium, and must keep the
property in good repair and
carry out all repairs and
maintenance to do so.
- The deposit is paid by
the Purchaser on the entry
of the contract. The deposit
paid will generally be less
than 10% and where
applicable, will include the
First Home Owner’s Grant. It
may itself be paid by
instalments, and will be
given direct to the Vendor,
and not held by a deposit
holder until completion.
- The Vendor retains legal
title until completion. That
is, the Purchaser does not
have title to the property
transferred into their name
(and is therefore not the
“owner”) until the final
instalment of the price is
paid or the vendor finance
is paid out by a refinance
or sale.
- Default under the
Contract will result in late
payment charges. If the
Contract is terminated, the
deposit and all instalments
paid are non refundable and
are kept by the Vendor.
- The Purchaser can pay
out the balance price under
the Contract before the due
date for completion, but
must pay all payments due to
that date and an early
completion charge.
- The Vendor needs to provide a Credit Code Disclosure Statement with the Contract and a Statement every six months to comply with the Consumer Credit Code.
The Lease Option
Where Vendor Finance consists of payments consisting of a mixture of rent and option fees, then it is known as rent to buy, rent to own or rent now, purchase later. These are documented by way of a Residential Tenancy Agreement and an option for sale, hence the abbreviation, Lease Option.
The Residential Tenancy Acts in each State have a Schedule which contains the standard form of Residential Tenancy Agreement to be used in that State. In some States, a different form is prescribed for short term leases as compared with longer term leases. The Residential Tenancy Acts prohibit any amendments to those standard forms.
Therefore, all that needs to be done is for the particulars to be inserted, namely the names and addresses of the landlord and tenant, the address of the property, the rent, and how it is to be payable, the term of the lease, the commencing date and the terminating date. Often the bond requirement is omitted.
The option is a separate document to the Residential Tenancy Agreement. The Sale of Land or Conveyancing Acts in each State provide for certain inclusions, but apart from that, the form of the option is left to the discretion of the drafter of the option. There are many precedents for call options available to assist in drafting the option. In most states, a cooling off warning must be attached, and in some states, a contract summary or a full Contract for Sale must be attached.
Technically, the option is a ‘call option’. This means that the purchaser takes an option to purchase the property. As a taker of the option, it is up to the purchaser to decide whether or not to proceed with the option, which is technically known as exercising the option. Because options are granted for a fixed period of time, then unless the option is exercised within that period of time, the option will lapse.
The main task of the person who drafts the option is to document the payment of the option fee. It must be documented so that it properly reflects the intention that it be credited as part of the deposit to be paid under the Contract for Sale, which comes into existence when the option is exercised. This credit is colloquially referred to as the ‘rent credit’.
The Second Mortgage carry back
Where Vendor Finance consists of payments consisting of a mixture of principal and interest, then it is known as carry back finance. Because the title to the property goes into the name of the purchaser, the documentation takes the form of a second mortgage, which is to rank after the first mortgage upon the property.
The second mortgage is no different in form from a first mortgage, although some drafters like to add a clause that a default under the first mortgage is to be treated as a default under the second mortgage. Often, but not always, the consent of the first mortgagee to the entry of the second mortgage will be obtained. The consent may be given by letter, or in the form of a Deed of Priority. The second mortgage will either be registered upon the title to the property, or a Caveat will be registered to protect the second mortgage.
Disclaimer: The information and advice contained in this commentary is: (a) general in nature; (b) intended to draw attention to certain items to be discussed with a professional adviser; (c) not intended to provide specific advice; (d) takes no account of particular facts and circumstances; and (e) is not to be relied upon for any purpose.; and (f) is copyright, and must not be used other than for private or educational purposes and is not to be published in any form without the prior written consent of Anthony J Cordato.
Anthony J Cordato and Cordato Partners Lawyers disclaim all liability and responsibility to the fullest extent available at law. Liability limited by a scheme approved under Professional Standards Legislation
