Home Uncategorized WHERE NEW DISCREPANCIES ARE FOUND ON RE-PRESENTED DOCUMENTS

WHERE NEW DISCREPANCIES ARE FOUND ON RE-PRESENTED DOCUMENTS

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by Old Man on Wednesday, October 5, 2011 at 4:07pm

QUERY FROM HM

Dear Mr.Old Man,

I was confused by this following situation, could you kindly clarify this for me:

The docs was refused due to the discrepancies. As per instruction of the applicant, we sent these docs to the Ben for correction.After that, we receiced the new one which were corrected the some discrepancies but not all raised in our notification to the applicant. I know the issuing bank should give only single notice to the applicant. So in this case, should we do to advise the discrepancies not be corrected to the applicant?

Thank you very much for your help.
—————

ANSWER

Hi,

The principle “single notice of refusal” in sub-article 16(c) applies whether the documents are a first presentation or a presentation on the basis of corrected documents. That is to say, if the re-presented documents contain new discrepancies (including discrepancies cited in the first notice but not corrected), the issuing bank that decides to refuse to honour must give a further (single) notice to that effect to the presenter no later than the close of the fifth banking day following the day of presentation.

Please note that when an issuing bank determines that a presentation does not comply, it may in its sole judgment approach the applicant for a waiver of the discrepancies.

As to your case, you may notify the applicant of the further discrepancies of the re-presented documents. But don’t forget to give a further notice of refusal to the presenter within 5 banking days from the date of receipt of the re-presented documents. Please note that failure to give such a further notice within the five day rule would render your bank liable to honour the documents.

Best regards,
Mr. Old Man

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9 Comments

  1. mrhero2014

    September 25, 2013 at 4:09 am

    Dear MR.old mannice to be friend of you over here, i hope you are fine and doing wellin the respect of replaced discrepant documentsi sent message to local bank, precluding it from claiming that replacement documents are not complying which represent a fresh presentation along with old clean documents,today i had a call from the bank asking about the practice of replaced documents will be considered new one and they must examine them too.i want your help to provide ICC official opinion in this respect to support my official reply to them.i knew that R 241 , R 324 and TA 609 could help in this respect but i could not reach them (have no access or way to get currently)could you please provide quotation of them or any other opinion that you find it can help me in my issuebest regards and many thanksAhmed – Egypt

    Reply

  2. mroldmanvcb

    September 25, 2013 at 2:09 pm

    Ok you' ll have them soon.

    Reply

  3. mrhero2014

    September 25, 2013 at 10:09 pm

    thanks a lot for your usual support

    Reply

  4. mroldmanvcb

    September 26, 2013 at 10:09 am

    R241Issue 1The issue is whether a beneficiary under an irrevocable credit is permitted to replace any discrepant documents with conforming documents, provided it is still within the validity date of the letter of credit. The letter of credit does not contain any statement that documents must be conforming on first presentation.Issue 2The issue is, if the answer is affirmative, whether this can be done without approval of the opening bank.….ICC ANALYSIS/CONCLUSION Issue 1AnalysisThe beneficiary and the remitting bank always have the possibility of putting the documents in order provided this is done before expiry of the credit, and that the documents are then presented within the time allowed in the terms of Article 43 UCP 500, and provided also that the documents still comply with the credit terms.ConclusionThe answer is affirmative.Issue 2AnalysisThis can be done without the specific approval of the opening bank if the substituted documents or corrected documents are re-presented within the validity of the credit, the conditions of UCP 500 Article 43 and any other condition stipulated in the credit and/or if the documents now comply with the terms and conditions of the credit.ConclusionThe answer is affirmative.

    Reply

  5. mrhero2014

    September 26, 2013 at 1:09 pm

    this would help me a lot, thanks a lot for your usual co-operation.i'm in await for the other opinions, if you pleasekind regards

    Reply

  6. mroldmanvcb

    September 26, 2013 at 4:09 pm

    Official Opinion R324 – 1998/99 From UCP500 – Sub-Articles 13(a) and 14(d) QUERY Modified documents which arrive after the expiry of the creditBeneficiary effects shipment under a documentary credit and presents documents to the negotiating bank. On receipt of the documents by the issuing bank, it identifies a discrepancy and advises that it is holding documents at the disposal of the negotiating bank, without notifying the applicant of the discrepancy.Modified documents are sent to the issuing bank, but by the time of receipt the credit has expired.Can modified documents which arrive after the expiry of the credit be refused by the issuing bank? Will such refusal affect a bank's reputation? ANALYSIS/CONCLUSION Analysis and conclusionDocuments and/or individual corrected documents must be re-presented to the nominated or issuing bank within the credit expiry and/or period for presentation specified in the credit.The answer in this case would depend on where the letter of credit expired. Since you state that the documents were negotiated, the place of expiry must have been at the counters of the negotiating bank.Such a refusal is in line with the responsibilities stated in UCP.If the documents were presented to the negotiating bank within the credit's validity, but did not reach the issuing bank within the validity date, the issuing bank would nevertheless be obligated to reimburse the negotiating bank if the documents were in order.————Official Opinion TA677revAnalysis It is not for an issuing bank to dictate what a beneficiary or other presenter may or may not do in order to achieve a complying presentation. In the normal course of events, it is within the rights of a presenter to request the return of discrepant documents and have them corrected, where possible. It is also its right to replace discrepant documents with corrected ones. Until the documents are honoured or negotiated, they remain the property of the presenter. It is also not for the issuing bank to request such certificates from the nominated bank in order that reimbursement be effected for any honour or negotiation that has transpired.

    Reply

  7. mrhero2014

    February 15, 2015 at 9:21 pm

    Dear MR.old man
    thanks alot for valuable views and comment, i asked you about correction and representation of ducuments, but i have faced with a new situation that requires your experinced view and opinion.

    the situation is,

    we are the issuing bank
    1-refused documents due to discrepant invoice.
    2-the presenter sent new invoice to clear discrepancies.
    3-we consider this as new fresh presenation and replaced new invoice with the old one to check the documents once more.
    4-we noticed vital discrepancy in packing list (not pointed out in our 1st refusal) due to sight mistake
    the question is, can we pointed out this discrepancy that already existed in the first presentation but we failed to point out in our first refusal?

    can we issue another advice of refusal respect packing list (not replaced)

    Regards
    Ahmed
    Egypt

    Reply

  8. mrhero2014

    February 15, 2015 at 9:25 pm

    sorry
    but is there any icc opinion to support our action
    Thanks

    Reply

    • mroldman

      February 17, 2015 at 7:56 pm

      Hi,

      You can raise discrepancies (if any) on the re-presented documents only. You cannot raise the discrepancies on the first presentation that you missed to point out in your first notice of refusal, i.e., you cannot issue another notice of refusal with respect to the discrepancy on the packing list.

      At your request, please find quotation of ICC Opinion TA754rev:

      QUOTE
      The additional discrepancy is not to be considered, as banks only have one opportunity to raise discrepancies for each presentation. In this case, since the additional discrepancy pertained to documents presented in the first presentation, it should have been identified at the time the first presentation was made and as part of the initial refusal notice.
      UNQUOTE

      Kind regards,
      Mr. Old Man

      Reply

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