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WHERE BENEFICIARY REFUSES TO PAY THE NOMINATED BANK'S CHARGES

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QUERY

Anonymous # 2. December 2010, 17:35

Thank you Mr Old Man.

I ask for your opinoin on another issue in the case as I descibed earlier in this thead. As I said, L/C stipulates that charges of the nominated bak are payble by the beneficiary.
Despite that, the beneficiary presented documents requesting payment and refused to pay those charges or at least simply didnot pay charges. Would such a case makes a discrepancy and non-comlying presentation?

I have in mind definition of the complying presentation from article 2 of UCP600 saing "Complying presentation means the presentation that is in accordance with the terms and conditions of the credit…". Further, L/C issuing bank is obliged to pay charges of the nominated bank, but it has the right to refuse payment of L/C documents and to act in accordance with article 12 of UCP600, stating discrepancy "Beneficiary refused or not paid charges of ABCDEFGH bank." That makes good "negotiating position" for the issing bank. The issuing bank is than in a position a) to act as requested by the beneficiary, or b) to deduct charges from proceeds (article 37 of UCP600), or c) to refuse payment and finish by returning documents to the presenters.
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COMMENTS

Mr. Old Man # 3. December 2010, 12:50

Hi,

According to sub-article 37 (c), a bank instructing another bank to perform services is liable for any commissions, fees, costs or expenses (“charges”) incurred by that bank in connection with its instructions. If LC states that charges are for the account of the beneficiary and charges cannot be collected or deducted from proceeds, the issuing bank remains liable for payment of charges. For example, if LC states that all charges (including advising charges, reimbursement charges…) outside the issuing bank’s country are for the beneficiary and the beneficiary refuses to pay such charges, the issuing bank remains liable for payment of charges.

Back to your particular case, it is true that in accordance with sub-article 12 (a) the nominated bank is not obliged to act on its nomination. Therefore, if the beneficiary refuses to pay the nominated bank for charges as instructed by the LC, the nominated bank would rather refuse to act on its nomination, i.e., refuse to honor the documents, than agree to honour and then claim charges from the issuing bank.

I do not think the beneficiary’s refusal to pay charges constitutes a discrepancy.

Best regards,
Mr. Old Man
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Abrar Ahmed # 4. December 2010, 01:17

A stipulation on the LC by the issuing bank to the effect that "charges of the nominated bank are payable by the beneficiary" without any further qualifying conditions to provide for the the situation where payment is refused, is in my view, not an express modification to sub-art. 37c, and therefore, the issuing bank would remain ulitimately liable to the nominated bank for its settlement.
However, as to whether a nominated bank should act on its nomination, depends on whether such nominated bank is also a confirming bank. In this case, it has an obligation to honour, and it is only on presentation of documents, that the nominated bank's (with the exception of the confirmation fee)charges are incurred. Whilst the confirming bank may be in a position to ensure that its confirmation fees are paid in advance of its adding confirmation, it would not be in a position to deduct "negotiation fee" and the like, until documents are presented. Although unlikely, an outright refusal by the beneficiary to allow a deduction of such fees from the proceeds, would automatically provide for the nominated bank to recover these charges from the issuing bank under provisions of sub-art.37 c.

The position of a non-confirming nominated bank is different. It can choose to act, or not act on its nomination. In this case, in consideration of acting on its nomination, it may wish to impose its own conditions for so acting (sub-art 12a),such as an explicit agreement that the beneficiary agrees to deduction of the nominated bank's charges.

As to whether a refusal to pay nominated bank's charges would constitute a discrepancy, Article 2 refers to a "presentation" which is defined as the act of delivering documents, or the documents themselves, so delivered.

The determination as to a "complying presentation" is restricted to an examination of the documents only, against the LC terms and UCP. Any other conditions in the LC not directly related to the document examination process (conducted in accordance with Article 14) is superfluous, and should not compromise the beneficiary's right to receive payment.
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Mr. Old Man # 4. December 2010, 06:57

Very very excellent!!!
Appreciated, Abrar.

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23 Comments

  1. anonymous

    December 8, 2010 at 9:12 pm

    zost writes:Dear Old Man, Dear Abrar, thank you for your opinion but I still think that beneficiary's refusal to pay charges of the issuing bank constitutes a discrepancy, if the payer of these charges is the beneficiary and that is defined in the L/C. I already quoted (a part of) Complying Presentation definition of art. 2 from UCP. You certainly will agree that independently of the acts of a nominated (but not confirming) bank, the issuing bank has the right and is authorized to check whether presented documents constitute the comlying presentation. That include a) examination of documents (as per art. 14 of UCP) and b) examination whether all other L/C terms are complied with, including as well whether L/C charges are paid as per L/C terms. If you do not agree and still think that a refusal to pay charges as defined in L/C terms does not consist a discrepancy, than such a logic must lead you to conclusion that, for example, a presentation after expiry date is not a discrepancy – as Abrar said "…complying presentation is restricted to an examination of the documents only" .—– Let's investigate in a very practical manner this case from other side, i.e. how an issuing bank could secure its interest and what conflictive situation that could make. So we have: 1) beneficiary refuses to pay charges, 2) beneficiary sends request for payment and L/C documents to the advising or nominated bank reqesting XXXXXXXX USD for these documents, 3) that bank sends documents to L/C issuing bank requesting payment of XXXXXXXX USD. What the issuing bank could do: a) It is not willing to pay charges of the advising/nominated bank as it cannot refund this amount from the applicant, b) it can not act in accordance of art.16 of UCP600 as it have not any discrepancy as per your opinion, c) it have the clear request to release documents against amount of XXXXXXXX USD so it can deduct charges amount from documents amoun, but it can not release documents to the applicant, and finally d) it must pay documents amount plus charges amount in spite of clear fact that all conditions of its L/C are not respected. —- So, how an issuing bank could secure not to pay charges and to secure that all the terms of its L/C (not only article 14 of UCP) are complied with. Please still have in mind article 2 of UCP600 saying "Complying presentation means the presentation (not documents only!!!) that is in accordance with the terms and conditions of the credit" as I quoted earlier. Please also have in mind that article 37. of UCP is titled "Disclaimer for Acts of an Instructed Party" meaning "… of an Instructed Bank" as no other parties are metioned in article 37. Please also have in mind 3rd paragraph of article 37.a. Kindest regards.

    Reply

  2. mroldmanvcb

    December 8, 2010 at 10:12 pm

    My previous answer remains unchanged. I hope Abrar will give his excellent answer!

    Reply

  3. abrar2

    December 8, 2010 at 11:12 pm

    Dear ZostI'm not sure whether I can add anything of further value, but in the example of a presentation after expiry, (where you suggest that since one shouldn't look beyond the document examination, one may disregard any prevailing LC expiry dates, it should be noted that whereas the documents may be compliant, the presentation would specifically not be compliant under provision of sub-art 6 d i and 6 e of UCP600. In this case, Art. 14 (which limits itself to examination of the documents) and Art. 6 (which deals with expiry, presentation place, and availability) should both be taken into account. You will note that sub-article 37 c (in fact the whole of the article) makes clear that the issue of charges, or its non-payment ultimately reverts to the issuing bank. In the scenario under discussion, a refusal by the beneficiary to pay charges would lead ultimately to the issuing bank required to settle the gross amount, but deduction of its own charges from the applicant's account. The applicant may protest but the issuing has precedence under sub-art. 37 b. Actually, it should also be noted that generally, UCP does not govern over the relationship between the issuing bank and the applicant, nor between the applicant and the beneficiary, as these relationships are considered to be outside the LC contractual arrangements, viz. issuing bank- confirming bank-beneficiary.

    Reply

  4. anonymous

    December 14, 2010 at 4:12 pm

    Zost writes:Dear Abrar,Article 6 of UCP is fine, but your previous argument was "complying presentation" is restricted to an examination of the documents only"". If you stay with your argument, how you can determine the date of presentation examining ***L/C DOCUMENTS ONLY*** !?That was just one of many possible examples showing that an L/C issuing bank must not be restricted to "examination of the (presented L/C) documents only". The first of the examples is the definition of complying presentation from art. 2 of UCP 600 that I already quoted.After we solve this issue I am ready to return to other issues in the case as above.

    Reply

  5. abrar2

    December 15, 2010 at 1:12 am

    Admittedly, I should have stated (a position I later corrected on a following reply) that the presentation must be in accordance with sub-art 6 d i and 6 e, as regards presentation place, method of availability, and expiry, and as far as the document examination is concerned, this would be in accordance with Art 14.However, neither article govern the payment, or non-payment of bank fees. There would be nothing in the documents or in the presentation itself which would allow a bank to raise a discrepancy on this point.Art. 2 defines a "presentation" as : "..either the delivery of documents under a credit to the issuing bank or nominated bank or the documents so delivered". It defines a "complying presentation" as a presentation "..that is in accordance with the terms and conditions of the credit, the applicable provisions of these rules and international standard banking practice".Art 14 rules that the bank must base its determination of compliance by limiting the examination to the documents alone.So, a refusal to pay charges whether verbal or written, is not covered by the above articles, and moreover, since the rules reflect international standard banking practice, they are intended to direct the bank's focus to areas which are within their natural examination capacity, and not to areas which are essentially disputes between the beneficiary and the applicant, under a contract to which the bank(s) are not a party. Art 37 is intended to provide cover to banks for such disputes

    Reply

  6. anonymous

    December 16, 2010 at 6:12 pm

    Zost writes:Dear Abrar, you certainly agree that the definition in a L/C how banking charges are split between the parties is a common condition, as other conditions in L/C. You certainly agree that issuing bank MUST examine whether (ALL – not some) terms and conditions are complied with, as stated in art.2 (Complying Presentation) of UCP600. So, from where you "draw" your conclusion that all conditions have to be accomplished except whether and who paid the charges. And please decide clearly wheter you stay with your argument "complying presentation is restricted to an examination of the documents only" or not. If yes, how you can check the date of presentation if looking only at L/C documents and examining only L/C documents. The only difference between "date of expiry" condition and "who must pay charges" condition is that the first one (date of expiry) is mentioned in UCP600 and second one is not. And let's clear some missunderstandings: aaa) the title of art. 14 is "Standard for Examination of Documents" and not "Standard for Examination of L/C Conditions Complience" so it will not tell you how to check whether charges are paid and whether L/C documents are presented in time, b) the title of art. 37 is "Disclaimer for Acts of an Instructed Party" so it explains relationships between the banks and it cannot release the beneficiary from the obligation to pay L/C charges if so defined in L/C. (Please, please, teach me how to format my comments and to split them in paragraps!!)

    Reply

  7. abrar2

    December 21, 2010 at 7:12 pm

    Dear Zost Sorry for the late response. It appears that we may have to agree to disagree. :-)A "complying presentation" requires examination for compliance of the documents themselves, against LC terms and UCP provisions. Whilst it may be a condition of the LC that charges are payable by the beneficiary, a refusal to pay (whether delivered orally, or by written correspondence) cannot be considered to be a part of the document presentation. Determination of compliance is based solely on the documents themselves, and the act of the presentation itself, in accordance with LC prescribed time limits, instalments, presentation period, latest shipment date, etc.Banks charge a fee for providing a service, and is entitled to recompensation. Whilst the LC may stipulate who is to pay such charges, and to whom such charges are to be paid, UCP recognises that the issue of non-payment ultimately reverts to the party giving the instruction. Had it not been so, and had it instead, beeen the ICC Commission's intention for a bank to refuse a presentation on the grounds of the beneficiary's refusal to pay charges, there would have been no need to incorporate the provisions under Article 37, and a separate express provision would have been included to allow for refusal on this basis.

    Reply

  8. anonymous

    December 23, 2010 at 5:12 pm

    zost writes:Dear Abrar, OK. As I see, you do not agree that all terms and conditions must be complied with before honouring, and that the issuing bank must limit its examination on L/C documents only, and that the definition "complying presentation" does not include (all) terms and conditions of the credit. OK, but just recall previous UCP (UCP500) and provision from these UCP, quote "An irrevocable Credit constitutes a definite undertaking of the Issuing Bank, provided that the stipulated documents are presented to the Nominated Bank or to the Issiond Bank and that the terms and conditions of the Credit are complied with." (article 9.a. of UCP500), So, do you really believe that the international practice changed so dramatically that an issuing bank is no more obliged to check complience of ***ALL*** L/C conditions, including whether its (issuing bank) charges are paid as per L/C conditions?? —- And when the date of presentation (as one of L/C conditions) is concerned, please allow me to paraphrase your own conclusion ***QUOTE: "Whilst it may be a condition of the LC that L/C documents must be presented by the beneficiary until stipulated Date of Expiry, a failure to present L/C documents in time (whether that stated orally, or by written correspondence) cannot be considered to be a part of the document presentation. The determination as to a "complying presentation" is restricted to an examination of the documents only, against the LC terms and UCP. Any other conditions in the LC not directly related to the document examination process (conducted in accordance with Article 14) is superfluous, and should not compromise the beneficiary's right to receive payment. Consequently, my conclusion from above paraphrazing is that a bank cannot refuse to honour "late presentation" because that cannot be determined from examination of L/C documents only. Such an oral statement about date of presentation or a statement in a writen document which is not a part of L/C documents must not be a part of documents examination as defined in article 14. of UCP600". END OF QUOTE *** —- When article 37 is concerned I repeatedly remind you that the title of this article is "Disclaimer for Acts of an Instructed Party", so any relationship between L/C beneficiary and the issuing bank can not be regulated by Article 37.

    Reply

  9. anonymous

    December 23, 2010 at 7:12 pm

    zost writes:Dear Old Man, I've tried to post my replay to Abrar's last comment. After that my reply and Abrar's comment disappeared. Could that be fixed. Many thanks.

    Reply

  10. mroldmanvcb

    December 23, 2010 at 9:12 pm

    Hi Zost, Abrar's comment and yours are still there!

    Reply

  11. anonymous

    December 24, 2010 at 3:12 pm

    Zost writes:Dear Mr. Old Man, thank you very much. I see the comments now.

    Reply

  12. anonymous

    December 24, 2010 at 4:12 pm

    Anonymous writes:Dear Abrar, just a little supplement to Article 37 of UCP600 and my previous comment: "A beneficiary can in no case avail itself of the contractual relationships existing between banks …" (article 4.a. of UCP600). The point is that the right of the issuing bank to claim banking charges to be paid by the beneficiary as per L/C terms or to refuse payment and to act as per article 16 of UCP600 (if the charges are not paid) is not restricted or forbidden by the provisions of article 37 of UCP600 and the like.

    Reply

  13. anonymous

    December 25, 2010 at 1:12 pm

    Anonymous writes:hi,Back to back LC claims that seller and buyer will not know each other. I have known that B/L can be switched to this effect (B/L contains the shipper's name isnt it).How about packing list – is it possible to switch packing list as well in back to back LC as that contains the sellers company name as well?Thanks

    Reply

  14. mroldmanvcb

    December 25, 2010 at 11:12 pm

    – UCP 600 (k): The shipper or consignor of the goods indicated on any document need not be the beneficiary of the credit. – I think to comply with the requirements under the master L/C, the beneficiary under the master LC can substitute his own documents (including invoice, draft and even packing list…) for those issued or prepared by the supplier.

    Reply

  15. abrar2

    December 29, 2010 at 12:12 am

    Originally posted by anonymous:

    Anonymous writes: Dear Abrar, just a little supplement to Article 37 of UCP600 and my previous comment: "A beneficiary can in no case avail itself of the contractual relationships existing between banks …" (article 4.a. of UCP600). The point is that the right of the issuing bank to claim banking charges to be paid by the beneficiary as per L/C terms or to refuse payment and to act as per article 16 of UCP600 (if the charges are not paid) is not restricted or forbidden by the provisions of article 37 of UCP600 and the like.

    Dear ZostI’m afraid that that this discussion has probably reached a stalemate, but what I will say is that if you review my comments of 14.12.10, you will note that I tempered my view by stating that the examination must be limited to the document themselves and to the overall act of presentation itself. I stated that the presentation must be in accordance with sub-art 6 d i and 6 e, as regards presentation place, method of availability, etc, and in accordance with Art 14, with regard to the documents themselves. However, neither article governs the payment, or non-payment of bank fees. There would be nothing in the documents, or in the presentation itself which would allow a bank to raise a discrepancy on this point.Let’s go back to the original premise that banks deal in documents only, so the condition that a beneficiary is to pay charges cannot be regulated through an examination of the documents themselves, nor by the act of “presentation” itself. The fall back must be sub-art 37 c, which provides for this specific scenario.It is true that Art 37 does not deal with the relationship between the beneficiary and the issuing bank, but is however provided for avoidance of doubt, that where an intermediary bank acts on behalf of the issuing bank as an agent, it does so at the full risk of the applicant (through the issuing bank).As regards sub-art. 4 a, I should point out that the intention behind the provision, is to rightly ensure that the beneficiary cannot exercise recourse or defence in respect of a claim, by reference to the underlying contract between the issuing bank and the applicant, or that between the banks themselves.

    Reply

  16. anonymous

    January 12, 2011 at 5:01 pm

    Zost writes:Dear Abrar, I am still interested in your answer to my previous question, quote: "OK. As I see, you do not agree that all terms and conditions must be complied with before honouring, and that the issuing bank must limit its examination on L/C documents only, and that the definition "complying presentation" does not include (all) terms and conditions of the credit. OK, but just recall previous UCP (UCP500) and provision from these UCP, quote "An irrevocable Credit constitutes a definite undertaking of the Issuing Bank, provided that the stipulated documents are presented to the Nominated Bank or to the Issiond Bank and that the terms and conditions of the Credit are complied with." (article 9.a. of UCP500), So, do you really believe that the international practice changed so dramatically that an issuing bank is no more obliged to check complience of ***ALL*** L/C conditions, including whether its (issuing bank) charges are paid as per L/C conditions??"

    Reply

  17. anonymous

    January 12, 2011 at 5:01 pm

    Zost writes:Dear Abrar, the premise that banks deal in documents only means that the bank do not examine the goods, but they examine the documents (required by the L/C and presented by the beneficiary) representing the goods and its state and noting more. Other conditions of L/C are to be checked other way. As I said earlier, it has been more clear in article 9 of UCP 500. If the opposite would be thrue than the documents presentation date cannot be checked at all (from documents presented by the beneficiary). But we still check the date of presentation, isn't we?

    Reply

  18. anonymous

    January 12, 2011 at 5:01 pm

    Zost writes:Dear Abrar, I think we progress but slowly. We know now that article 37 of UCP is not relevant for this issue. I think we can progress better if you could give a direct answer to some questions. One of these questions (my comment from 14 Dec.2010) was "Article 6 of UCP is fine, but your previous argument was "complying presentation" is restricted to an examination of the documents only". If you stay with your argument, how you can determine the date of presentation examining ***L/C DOCUMENTS ONLY*** !?". Article 6 of UCP600 does not help you, it only gives you the right to check the date of presentation, but still in the limits of your statement "complying presentation" is restricted to an examination of the documents only" if that statement is true. So, how really in the case of unpaid charges is not permitted to check anyting beyond L/C docs., but it is permitted when checking the date of presentation??? In other words – how (from where) you check the date of presentation as this detail is not quoted regularly in L/C documents.

    Reply

  19. abrar2

    January 14, 2011 at 7:01 am

    Although I had intended not to prolong the argument…..I believe that to get to the issue here, we must try and focus on the basic issues: UCP600 dictates that an issuing/confirming bank must honour if the documents presented constitute a "complying presentation". A "complying presentation" means a presentation that is in accordance with the LC, UCP600 and international standard banking practice.A "presentation" is defined as either the act of deivery of documents to the bank, or the documents themselves.So, in essence, we need to focus on the "presentation" itself. For the purposes of this argument, we may discount the interpretation of a "presentation" as being the act of delivery. Therefore, what we are left with, is the interpretation that the "presentation" constitutes the documents themselves.How does one examine the documents? We then apply the rule that the documents must be "…in accordance with the LC, UCP600 and international standard banking practice". The examination standards are concenrated in Article 14. It is of course a given that in any case, the "presentation" must be made on or before the LC expiry date (sub-art 6d (i) and 6e).Thease are the limits of reference to examination standards under UCP, and so you can see that there is no provision for a bank to reject a "presentation" on the basis of the beneficiary's unwillingness to pay charges, because, the situation is not covered by a documentary condition. The refusal to pay charges does not form part of the "presentation". This is why Art 37c provides guidance and makes clear that non-payment of charges eventually revert to the issuing bank. Although the practice is to be discouraged, to counter this situation, many banks often include a directive to the advising bank not to advise the LC unless it has first collected its charges. Alternatively, one could consider a documentary requirement under the LC, along the lines of : "Beneficiary's certificate, certifying having settled/ or agreeing to settle all outstanding charges of XYZ bank" I would respectfully suggest that if you feel strongly about the issue, you may wish to pursue an Official ICC Opinion through your National Committee.

    Reply

  20. anonymous

    January 21, 2011 at 6:01 pm

    zost writes:Dear Abrar, this discussion becomes irrelevant. I maybe have stupid arguments and stupid questions for you, but you certainly have good answers to these questions. I really would like to have your answers to some of my previous questions. I am ready to to answer all your questions. I repeat some of my previous questions: 1) Do you really believe that the international practice changed so dramatically that an issuing bank is no more obliged to check complience of ***ALL*** L/C conditions, including whether its (issuing bank) charges are paid as per L/C conditions?? I posed this question on 23rd December 2010 in context of article 9 of UCP500, 2) How you can check the date of presentation if looking only at L/C documents and examining only L/C documents? This question is in my comment from 16th December 2010. 3) How really in the case of unpaid charges is not permitted to check anyting beyond L/C docs., but it is permitted when checking the date of presentation??? In other words – how (from where) you check the date of presentation as this detail is not quoted regularly in L/C documents? This question (the same as previous one) is in my comment from 12th January 2011. Thank you for not ignoring my stupid questions this time.

    Reply

  21. abrar2

    January 21, 2011 at 9:01 pm

    Dear ZostYou must understand,the questions are not at all stupid, but admittedly challenging and difficult to answer! Nothing is ever black and white, and I do not profess to claim that I am right, but simply that, based on the tools available (UCP600, ISBP, etc) I am not sure whether the presentation may be rejected. However, I will devote some more time to your specific questions, and revert with my comments in due course

    Reply

  22. anonymous

    February 24, 2013 at 2:02 am

    aelhoussainy writes:what if a beneficiary refuses to pay the VALUE (Full amount of the shipping documents) of an advised L/C after the goods have arrived and received by the beneficiary. Is the beneficiary bank obliged to pay the amount to the applicant's bank since the beneficiary bank has sent MT754 to the applicant's bank.Thanks in [email protected]

    Reply

  23. mroldmanvcb

    February 24, 2013 at 11:02 am

    Dear Aethoussainy,Could you please clarify your question?Why does beneficiary refuse to pay the value of the documents of and advised LC? Why has the beneficiary received the goods?

    Reply

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