Brazzill & Ors v Willoughby & Ors

Brazzill & Ors v Willoughby & Ors

A valid trust was created over all monies standing to the credit of the segregated account at the Bank of England pursuant to the FSA Notice. The beneficiaries of the trust are all customers who made deposits with KSF between 3 and 7 October 2008, whether or not matching funds were actually transferred into the account. The trust operates such that KSF is entitled to reimbursement from the account for repayments made to depositors. The Transfer Order operated to assign the rights of Edge Depositors to FSCS/HMT, who are entitled to the corresponding sums in the account. There are no equitable or restitutionary remedies (including subrogation) available to FSCS/HMT beyond the assignment....

Parties
Applicant: Patrick Brazzill; Applicant: Alan Bloom; Applicant: Thomas Burton; Applicant: Margaret Mills; Respondent: Bernadette Willoughby; Respondent: Kaupthing Singer & Friedlander (Isle of Man) Ltd; Respondent: Transport for London; Respondent: HM Treasury; Respondent: Financial Services Compensation Scheme
Jurisdiction
England and Wales
Judgment Date
10 July 2009
Procedural Posture
Ordinary Application for Directions (insolvency) / Judgment After Trial of Preliminary Issues
Outcome
Declaratory judgment with directions; trust declared and beneficiaries identified; assignment to FSCS/HMT confirmed; no subrogation or restitutionary remedy for FSCS/HMT; losses to be borne pro rata among beneficiaries.
Legal Topics
Creation and Operation of Trusts in Insolvency, Assignment of Rights Under Statutory Compensation Schemes, Interpretation of Regulatory Notices and Statutory Instruments, Ranking of Claims in Insolvency, Restitution and Subrogation in Insolvency Context

Case Brief

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Parties

Patrick Brazzill

Applicant

Alan Bloom

Applicant

Thomas Burton

Applicant

Margaret Mills

Applicant

Bernadette Willoughby

Respondent

Kaupthing Singer & Friedlander (Isle of Man) Ltd

Respondent

Transport for London

Respondent

HM Treasury

Respondent

Financial Services Compensation Scheme

Respondent

Procedural Posture

Ordinary Application for Directions (insolvency) / Judgment After Trial of Preliminary Issues

  1. 1 Whether a valid trust was created over the sums in the segregated account at the Bank of England under the FSA Notice
  2. 2 Who are the beneficiaries of the trust and what are the terms of the trust
  3. 3 How withdrawals and repayments affect the trust and its beneficiaries

Ratio Decidendi

A valid trust was created over all monies standing to the credit of the segregated account at the Bank of England pursuant to the FSA Notice. The beneficiaries of the trust are all customers who made deposits with KSF between 3 and 7 October 2008, whether or not matching funds were actually transferred into the account. The trust operates such that KSF is entitled to reimbursement from the account for repayments made to depositors. The Transfer Order operated to assign the rights of Edge Depositors to FSCS/HMT, who are entitled to the corresponding sums in the account. There are no equitable or restitutionary remedies (including subrogation) available to FSCS/HMT beyond the assignment....

Court Disposition

Declaratory judgment with directions; trust declared and beneficiaries identified; assignment to FSCS/HMT confirmed; no subrogation or restitutionary remedy for FSCS/HMT; losses to be borne pro rata among beneficiaries.

Orders

  • A valid trust was created over all sums in the account.
  • All post-Notice depositors are beneficiaries, whether or not matched.