Led down the garden path…

This is the third article in my rant over the bad – in fact downright dangerous – advice my fellow insolvency practitioners are regularly giving out…

The first was about the bad advice being given to company owners, selling them a liquidation they didn’t want, need nor could easily pay for…

The second was about the failure to advise individuals that income based individual voluntary arrangements are a massive gamble…

This, my third, rant is again about the bad advice given to individuals, but on a more general level.

Let me explain…

Have you seen how debt advisers of all sorts, but particularly the IVA specialists, send husbands and wives, or couples, down the same debt solution at exactly the same time?  They argue that it makes perfect sense, that doing so is cost effective… yet that, at least for me, is manure, and I’m going to show you why…

First of all, a few key principles for you to take on board…

You, me, your kids, your parents, Uncle Tom Cobleigh and all are separate individuals in the eyes of the law.  We’re each our own entirely distinct legal entity.  It matters not that we are married, part of a family, related in any way – we are all our own separate legal being, with our own little package of assets and liabilities, and thus our own individual options for dealing with our financial problems. 

And, importantly, those options are often not mutually exclusive.   An option taken now doesn’t always stop another being taken later on.

Sure, there are a few complications when their are joint assets or joint debts, but the principle remains – we each have our own separate options, which we can take as and when we choose.

Let’s take a typical situation…. Husband (Basil) and wife (Sybil); Basil is a landscape gardener who chooses to run his little business through a limited company, in which he owns all the shares.  His normal work is maintaining your and my garden, doing a little building work from time to time, pathways, rockeries, decking, BBQs, that sort of thing.  A nice little business, but not enough to keep house and home, the family has to rely on his wife’s income too, especially as he had an accident a year or so ago – he twisted his back beating up his Morris 1100 and couldn’t work for 6 months.  Couple this with a foray into the buy to let market where a void period and some unexpected repairs as a result of the actions of a dodgy tenant and supporting one of his kids through university saw his debts built up.  He now has £50,000 in personal credit card and loan bills, each at their max, he’s now not even paying the minimum payments – the business isn’t doing as well as he’d hope as people aren’t spending like they used to on their gardens, and his bad back plays up from time to time, middle age is taking its toll.  There’s nothing but a few items of small plant and an inexpensive van in the company: it”ll generate £1,500 per month on a good month, more often than not a lot less, particularly in the winter months.  The buy to let is in negative equity – they’d taken out the maximum mortgage they could when they bought it, and have remortgaged a few times, using the money raised to buy Basil’s van and tools.  The buy to let is making a profit of £120 per month, after paying the mortgage, assuming everything goes hunky dory….

Feisty Sybil is a part time shop assistant and home maker.  When the debts started piling up she took on a few debts too – but at a far lower level, after all, she earns a lot less than Basil.  She’s got £20,000 of credit card debt, of which £15,000 is in her own name, £5,000 is a joint debt with Basil.

The family, Basil, Sybil and their three kids – Martha, 20, going through Wolverhampton Uni; Steve 16 and at Bilston Academy; and Sarah, 13 at Coseley School – all live in a cramped three bed semi on the Coseley/Bilston border.  A few years back, with the walls moving in, Basil, a dab hand at building, started on an extension above the garage.  But then he hurt his back, he couldn’t work and now he hasn’t got the money to finish it and doesn’t know when he will ever have.  The house is virtually unsaleable in its present condition, at best a buyer would pay a knock down price, leaving nothing in the kitty to set up home elsewhere after settling the mortgage.  Basil is hoping Sybil’s mother, Ethel, will leave them something in her will, but they’d be lucky to get £45,000 when she turns her toes up.  And that’s assuming it doesn’t all go in care home fees.  He/they have been holding on for that legacy – it might just provide the lifeline they so desperately need – but cantakerous old Ethel, whos’ yoyo’ed in and out of hospital over the last 18 months, seems to have 9 lives.

So you’ve got the picture – The Fawltys are a hard working, average, working class family who are trying to work their way through life, but have been hurt by a few things that all came together to put them into quite a difficult position.

So they go to see an insolvency practitioner.

This ‘expert’ recommends an IVA – a ‘joint IVA’ – the great thing is they’ll be able to substitute the need to pay the minimum payments on their debts with ‘one affordable payment’ of just £400 per month into the IVA – it will mean paying less and bring some certainty to the situation, they’ll be able to slep at night.  They’ll even keep their home; Basil will still be able to act as a director of his little limited company; they could keep the buy to let; and in 5 years time, they’ll be debt free – what they’ve not paid to their £65k of unsecured debt will simply be written off.  What’s more, them both going into an IVA right now would not only keep the IVA experts’ costs down, it would make things far simpler for them as they’d both come out of it at the same time, ten years before retirement.

Sounds reasonable?  Sure it does… but as I said, it’s appalling advice.

Let me tell you what taking that advice would lead to…Ethel’s legacy going into the IVA to pay the insolvency practitioner’s fees and Basil and Sybil’s creditors – that’s to say, the Fawlty family would see nothing of it; Basil and Sybil still having to pay £400 per month into the IVA for 5 years – these monies also going to the creditors to pay off the ‘capital sum’ and interest (with interest being charged at 20% to 30% pa); the IP getting about £20k in fees in total; etc… there are other implications too.  All in all a poor deal for the family.

So let’s pull the advice to bits…

The following is a key principle – please remember it…  ‘Just because one solution might be the best option right now for one person, doesn’t mean to say the other has to follow the same course at this exact point in time, even if ultimately it might be the best option for them too.’

Here’s another – both Basil and Sybil have their own full tool box of options each – these include (i) Best manage their cash, keeping themselves out of any formal insolvency; (ii) Keeping creditors at bay using the ‘token/no payment’ option; (iii) Debt Management Plan; (iv) IVA; and (v) Bankruptcy.

It’s vital they should assess their own individual options first, asking themselves ‘What’s the best for me at this particular point in time?’.  Then when they know what that option is, assess what that means for the other member of the couple.

So the steps are:

1)  What’s the best option for me?  Write down the pros and the cons for me.

2) If I take that option, what impact does that have on my partner?  Write down the pros and the cons for them.

3)  Are we prepared to live with the cons?  Could those cons be reduced, if not eliminated, by something either I or my partner could do?  If I’m not happy with the cons, and neither I nor my partner could reduce them, what’s my second best option and what are its pros and cons – the cons on both me and my partner?

4) Repeat steps 1) to 3) for your partner, assessing the pros and cons on both them and you.

5)  Put together a plan that you’re both ‘happy’ with.  Ask yourself, whether overall, this plan works and fits with what you both want to achieve.

6) Run with it…

Here’s what I would have advised in Basil and Sybil’s case…as you’ll see it’s a country mile away from what the other IP advised…

Basil should go into bankruptcy soon, and first – cost of doing so £700, debts written off £50,000 – it would be like picking a 70 to 1 certain  winner at Epsom, a great return on his money; he’d come out of bankruptcy in 12 months time. Sybil should keep her creditors at bay for that 12 months, using the token payment option; before Basil goes bankrupt, Sybil should become the shareholder and director of the company, taking responsibility for running it, with Basil becoming a mere paid employee – for just 12 months.  Then when he’s out of bankruptcty the roles would reverse – she’d go bankrupt, but before she did so, he’d take buy back her shares in the company and get appointed as its director.  Cost to her, £700, debts written off £20,000. Get Ethel to change her will, so the beneficiaries are Martha, Steve and Sarah, missing out the Basil/Sybil generation (she could always change it back in 24 months time if she’s still around!) – that way the legacy would not fall into the bankruptcy as ‘after acquired property’, it could be used to pay down the mortgage on their home or the BTL giving them a far better chance of a prosperous retirement.

An alternative to think about in 12 months time would be, if Ethel dies in the meantime and leaves her £45k to the kids, for some of that to be used, say 40%, £8k, to offer to her creditors in full and final settlement, if she really wanted to avoid bankruptcy.  The point is, she doesn’t necessarily have to follow Basil’s route – having ringfenced the legacy, she could take another solution then.  Watch, wait and see!

Result if plan A, of them both going bankrupt, him first, her later: No disruption to the business; total process 24 months when one or the other was in bankruptcy compared to 5+ years in an IVA; no assets lost – not even the home or BTL (unless they actually wanted to lose the BTL – they have the choice);  legacy kept within the family, doing it, rather than the creditors some good; no IP fees, whole process cost £1,400 (plus the cost of my advice), a little inconvenience and form filling, and the cost of writing one/two wills, compared to an IVA which would see over £69,000 spent, I’d argue wasted.

The Fawltys’ name may be made up but the facts are real,but in recent weeks I’ve seen 2 families, both where they’d been led down the garden path by so called experts with plausible yet downright dangerous advice, costing them money they couldn’t really afford.  You see, they suffered the outcome I ‘anticipated’ above, they will probably now never manage to rebuild their lives.

And that is inexcusable.  The IPs took them to the cleaners, their entire family, not just the ones in debt, but them all.

You see nothing will ever be a substitute for experience, professionalism and a single minded focus on getting the best outcome for the client … and with almost 30 years in the insolvency game, you can be sure anyone who comes to me for support will be getting these in abundance.  They will not be sailing into unchartered territory, they’ll get advice and support that will stand the test of time.

If you’re accustomed to using another insolvency practitioner and the story I’ve painted above is ringing true for you, I’ve a question for you…why?

The second golden rule is if you have big debt problems is…

‘Only choose an option other than bankruptcy if it better protects your income or assets’

The first golden rule has shown you if you go into bankruptcy, it’s almost certain that you’ll lose no income nor assets.

So, please ask yourself two questions

  • Will bankruptcy see me losing any income or assets that are important to me or my family?
  • Will the other solutions I’m thinking about taking better protect my income or assets?

The key point is that in the real world most other solutions don’t better protect your income or assets than bankruptcy.

So…

Why do it?

Come back here in a week’s time for some other essential facts…

Celebrity endorsement – 'of course we can trust them'

I’m early, I know, but this is a topic which for me could turn into a real rant…

And this is why….

Three weeks ago the Office for Fair Trading said on their website that it is giving the leading 50 payday lenders, who make up 90 per cent of the market, 3 months to change their business practices or risk losing their licences.  The OFT said it uncovered widespread irresponsible lending and failure to comply with standards. So much so that they’ve been told to change their ways.

The report said there were problems throughout the entire lifecycle of payday loans, from advertising through to debt collection, and all across the sector, including by leading lenders that are members of established trade associations.

The OFT’s report cited the following areas of non-compliance:

  1. lenders failing to conduct adequate assessments of affordability before lending or rolling over loans (lend today, worry about getting it back tomorrow – haven’t we been here before?)
  2. failing to explain adequately how payments will be collected (an education issue – when are we going to teach our kids to understand how money works?)
  3. using aggressive debt collection practices (well we all knew that, but just wait until they sell on the debts they can’t collect – they won’t be selling them on to cuddly debt collectors)
  4. not treating borrowers in financial difficulty with forbearance (see 1).

None of this should come as any surprise to any of us.

What really angers me though is how a good many of these and similar lenders to the vulnerable use celebrities to endorse their products… to suggest that somehow because someone who’s in the public eye, but knows nothing about what they are talking about, promotes their product, it’s all ok, that’s it’s all legit.

Let’s look at some of the celebrities endorsing the payday, pawn broking and consolidation loan companies:

Nicholas Parsons and those annoying puppets – Wonga (APR 4,214%)
Carole Vorderman – Firstplus, click here
Kerry Katona – surely the ultimate in irony, she’s been personally bankrupt – nothing wrong with that but why oh why would she come out now after bankruptcy and encourage others to borrow? (sorry, I suspect we’ve got the answer there?) – Cash Lady (APR 2,670%) – click here for her cheesy advert and here for a written interview (it’s priceless, apparently she’s a normal Joanne in the street with everyday bills to pay, like school fees and nannies!)
David Dickinson – The Money Shop (go on, I dare you, click on this, turn the volume up, but make sure you’ve a bucket handy).

The worst?  Difficult choice, all the wide toothy smiles, cheesy straplines, bright blue eyes, sunshine, young good looking mums doing normal things yet worrying about trying to make ends meet, the sexiness of and ease of taking out a lone….mmm, now let’s see…. my vote goes to a firm of pawnbrokers who use a talking sock to sell its loans – click here.  Yuk!

I’ve been talking in schools a lot recently, warning against the perils of payday loans – the ease with which money can be borrowed compared to how difficult it is paying them off.  You see lending to the vulnerable is big business, about 7 million new payday loans are taken out every year.  And the numbers and volume of loans are growing.

When I talk to the kids I point out that although the adverts for payday loans suggest they are take out to cover emergencies – car repair, water leak, computer drink spillage, that sort of stuff – that’s not what they are used for in reality – they are used to bridge short term gaps in normal day to day spending …you know when you’ve too much month left at the end of your money…

I also teach them that interest on payday loans runs on average at £25 for every £100 loaned for 30 days.  Yes, £25 for each £100…for just 30 days.  Can I make a suggestion?

..that the next time you walk along your local High Street past one of these shops, you stop and look in their window at their terms.  But make sure that you do a few stretches and bends first as you’ll find them on a pop up banner at or below knee height…in very small typeface…below the smiley, cheesy grins in the advert above.  So don’t forget to take your glasses and the Voltarol.

The OFT report went on to say that up to half of payday lenders’ revenue comes from loans that last longer than a month.  You see most loans are rolled over or refinanced, several times over.  So it’s not £25 for every £100 loaned, it’s much much more.

I just love that Wonga advert on television, don’t you?  Next time it’s on, listen carefully.  They make a big, and positive, thing that one quarter of their customers repay their loan in full and within time.

Putting to one side the fact that if you were charged over 4,000% interest, you’d do your very best to repay it in full and on time, isn’t that great news that so many people settle ‘early’?

No, not at all…

You see, I say when I go into schools, ‘flip it, that means that three quarters of people, that’s three times as many people, don’t repay on time as do’.  It’s advertising talk, turning a huge negative into a positive, hoping that no one notices.  And most don’t.

So perhaps it’s not surprising that Wonga’s accounts for 2011 showed it made a profit of £44m on turnover of £184m?  Not a bad profit for a business which is obviously having to spend a lot of money trying to capture market share…

I wonder just how great a business Wonga and the other payday lenders would have if people used the loans for what they were (arguably) designed for?  Or if interest rates were more reasonable?  But then again, their profits are assured for years to come because of bad education, human gullibility and fallibility!

But there’s another point…

Perhaps we ought to be asking ourselves more just what sort of world we are bringing our children in to?

A good many of people I know who live abroad have told me their views of the UK… that the only growth area we have is in debt.   What a sad indictment of the land we live in, the times we’ve created.

Perhaps we ought to be asking our MPs why they are doing absolutely nothing about the horrendously high interest rates payday lenders charge the most vulnerable members of our society? And why more time and resources are not being given to improving our children’s financial education?

I know of several insolvency practitioners who are preparing to upset the payday lenders’ rates as an ‘extortionate credit transaction’ under the Insolvency Act – something they can do after the borrower has gone into bankruptcy.  The problem is the very trigger for doing so means the insolvency practitioner typically has no money to fund an action – it could be a case of David v Goliath – on something that’s a matter of principle for the lender but has a small effect in the bankruptcy in terms of its impact on creditor dividends.  But wouldn’t it be great if, for the first time in a long time, the insolvency profession were to take a moral stance that those in powers and Joe and Joanne Public aren’t overly interested in?  Then, perhaps the public may not be as shocked as we are by the level of debt people and this country are in.

If however, you feel as I do that something just has to be done about these payday lenders, how they operate and use celebrities’ ‘good names’ and ‘mis-information’ to promote their products, why not write to your local MP – here’s how you find their details.

By the way, we’re quieter on the formal insolvency front than we have been for a good while – this isn’t a bad thing because we’re doing far more ‘positive’ work right now.  But what it does mean is that we have spare capacity for any liquidations, administrations and receiverships you may need carrying out.  Which of your clients are struggling so badly that they either need to call it a day or lose debt?

I’d really appreciate your feedback, good or bad, on my e-mails.

Paul Brindley
Midlands Business Recovery

‘Doing more for Black Country Businesses’

Celebrity endorsement – ‘of course we can trust them’

I’m early, I know, but this is a topic which for me could turn into a real rant…

And this is why….

Three weeks ago the Office for Fair Trading said on their website that it is giving the leading 50 payday lenders, who make up 90 per cent of the market, 3 months to change their business practices or risk losing their licences.  The OFT said it uncovered widespread irresponsible lending and failure to comply with standards. So much so that they’ve been told to change their ways.

The report said there were problems throughout the entire lifecycle of payday loans, from advertising through to debt collection, and all across the sector, including by leading lenders that are members of established trade associations.

The OFT’s report cited the following areas of non-compliance:

  1. lenders failing to conduct adequate assessments of affordability before lending or rolling over loans (lend today, worry about getting it back tomorrow – haven’t we been here before?)
  2. failing to explain adequately how payments will be collected (an education issue – when are we going to teach our kids to understand how money works?)
  3. using aggressive debt collection practices (well we all knew that, but just wait until they sell on the debts they can’t collect – they won’t be selling them on to cuddly debt collectors)
  4. not treating borrowers in financial difficulty with forbearance (see 1).

None of this should come as any surprise to any of us.

What really angers me though is how a good many of these and similar lenders to the vulnerable use celebrities to endorse their products… to suggest that somehow because someone who’s in the public eye, but knows nothing about what they are talking about, promotes their product, it’s all ok, that’s it’s all legit.

Let’s look at some of the celebrities endorsing the payday, pawn broking and consolidation loan companies:

Nicholas Parsons and those annoying puppets – Wonga (APR 4,214%)
Carole Vorderman – Firstplus, click here
Kerry Katona – surely the ultimate in irony, she’s been personally bankrupt – nothing wrong with that but why oh why would she come out now after bankruptcy and encourage others to borrow? (sorry, I suspect we’ve got the answer there?) – Cash Lady (APR 2,670%) – click here for her cheesy advert and here for a written interview (it’s priceless, apparently she’s a normal Joanne in the street with everyday bills to pay, like school fees and nannies!)
David Dickinson – The Money Shop (go on, I dare you, click on this, turn the volume up, but make sure you’ve a bucket handy).

The worst?  Difficult choice, all the wide toothy smiles, cheesy straplines, bright blue eyes, sunshine, young good looking mums doing normal things yet worrying about trying to make ends meet, the sexiness of and ease of taking out a lone….mmm, now let’s see…. my vote goes to a firm of pawnbrokers who use a talking sock to sell its loans – click here.  Yuk!

I’ve been talking in schools a lot recently, warning against the perils of payday loans – the ease with which money can be borrowed compared to how difficult it is paying them off.  You see lending to the vulnerable is big business, about 7 million new payday loans are taken out every year.  And the numbers and volume of loans are growing.

When I talk to the kids I point out that although the adverts for payday loans suggest they are take out to cover emergencies – car repair, water leak, computer drink spillage, that sort of stuff – that’s not what they are used for in reality – they are used to bridge short term gaps in normal day to day spending …you know when you’ve too much month left at the end of your money…

I also teach them that interest on payday loans runs on average at £25 for every £100 loaned for 30 days.  Yes, £25 for each £100…for just 30 days.  Can I make a suggestion?

..that the next time you walk along your local High Street past one of these shops, you stop and look in their window at their terms.  But make sure that you do a few stretches and bends first as you’ll find them on a pop up banner at or below knee height…in very small typeface…below the smiley, cheesy grins in the advert above.  So don’t forget to take your glasses and the Voltarol.

The OFT report went on to say that up to half of payday lenders’ revenue comes from loans that last longer than a month.  You see most loans are rolled over or refinanced, several times over.  So it’s not £25 for every £100 loaned, it’s much much more.

I just love that Wonga advert on television, don’t you?  Next time it’s on, listen carefully.  They make a big, and positive, thing that one quarter of their customers repay their loan in full and within time.

Putting to one side the fact that if you were charged over 4,000% interest, you’d do your very best to repay it in full and on time, isn’t that great news that so many people settle ‘early’?

No, not at all…

You see, I say when I go into schools, ‘flip it, that means that three quarters of people, that’s three times as many people, don’t repay on time as do’.  It’s advertising talk, turning a huge negative into a positive, hoping that no one notices.  And most don’t.

So perhaps it’s not surprising that Wonga’s accounts for 2011 showed it made a profit of £44m on turnover of £184m?  Not a bad profit for a business which is obviously having to spend a lot of money trying to capture market share…

I wonder just how great a business Wonga and the other payday lenders would have if people used the loans for what they were (arguably) designed for?  Or if interest rates were more reasonable?  But then again, their profits are assured for years to come because of bad education, human gullibility and fallibility!

But there’s another point…

Perhaps we ought to be asking ourselves more just what sort of world we are bringing our children in to?

A good many of people I know who live abroad have told me their views of the UK… that the only growth area we have is in debt.   What a sad indictment of the land we live in, the times we’ve created.

Perhaps we ought to be asking our MPs why they are doing absolutely nothing about the horrendously high interest rates payday lenders charge the most vulnerable members of our society? And why more time and resources are not being given to improving our children’s financial education?

I know of several insolvency practitioners who are preparing to upset the payday lenders’ rates as an ‘extortionate credit transaction’ under the Insolvency Act – something they can do after the borrower has gone into bankruptcy.  The problem is the very trigger for doing so means the insolvency practitioner typically has no money to fund an action – it could be a case of David v Goliath – on something that’s a matter of principle for the lender but has a small effect in the bankruptcy in terms of its impact on creditor dividends.  But wouldn’t it be great if, for the first time in a long time, the insolvency profession were to take a moral stance that those in powers and Joe and Joanne Public aren’t overly interested in?  Then, perhaps the public may not be as shocked as we are by the level of debt people and this country are in.

If however, you feel as I do that something just has to be done about these payday lenders, how they operate and use celebrities’ ‘good names’ and ‘mis-information’ to promote their products, why not write to your local MP – here’s how you find their details.

By the way, we’re quieter on the formal insolvency front than we have been for a good while – this isn’t a bad thing because we’re doing far more ‘positive’ work right now.  But what it does mean is that we have spare capacity for any liquidations, administrations and receiverships you may need carrying out.  Which of your clients are struggling so badly that they either need to call it a day or lose debt?

I’d really appreciate your feedback, good or bad, on my e-mails.

Paul Brindley
Midlands Business Recovery

‘Doing more for Black Country Businesses’

The first golden rule if you’ve got big debt problems…

The first golden rule if you have major debt problems is:

‘you should first look at personal bankruptcy because if you’re really in a lot of trouble with money, it’s almost always the best option’.

But I hear you say ‘isn’t this is the opposite of what you’d expect?  And what most debt advisers will tell you?

Yes, that’s right, so why do I say this?

  • In three quarters of cases all you lose is your unsecured debts: you lose no assets, not even your home;
  • It costs less than a thousand pounds to go bankrupt, far less than almost all of the other solutions you may have available;
  • You’re in bankruptcy for just twelve months – it will pass very quickly indeed.  Compare this to how long you have been juggling your finances.  IVAs, often recommended by debt advisers, insolvency practitioners and their ‘finders’ are typically for 5 years – can you see forward this far? Can you guarantee you’ll complete the IVA?
  • Often bankruptcy is far less risky a solution than your other options for dealing with your debts because you can learn how the process works, you can assess the outcome before you go into it – that’s because there are far fewer areas for compromise or negotiation than other solutions you may be thinking about;
  • There are no messy negotiations with your creditors – if you petition yourself, your bankruptcy is simply imposed on them, your creditors don’t get a choice.  They do in other solutions;
  • In just one quarter of cases – Insolvency Service figures, not ours, the Official Receiver takes a share of your ‘surplus income’.  He does this for 3 years.  Compare this with a typical IVA – 100% of cases, 5 years.  But, and it’s very important you note this, in a bankruptcy no one can make you work as long or as hard as you did before.  If you want to take some time out to re-assess where you want to take your life, you can.  You can take a lower paid job that’s less stressful.  You can reduce your income for the year of your bankruptcy, avoid an ‘income payments order’ – and once you’re discharged, it’s too late for the Official Receiver to seek any money from you, you’ll keep all the money you earn for yourself.  It’s a case of one year of ‘pain’ for ‘later gain’.  Generally only those who don’t bother learning how ‘income payments’ work in practice end up paying them, so learn about them!
  • If you are lucky enough to enjoy a windfall, say a legacy or a lottery win, you’ll only have to pay it into the bankruptcy – that is to say you can’t keep it – if you became entitled to it in the year of your bankruptcy.  Become entitled after you’ve been discharged and you keep it all!  Compare this with IVAs – 5 years-  and DMPs -unlimited.  I presume you’ve not got a crystal ball?  The point is that by petitioning for your own bankruptcy can mean you actually protecting your family’s wealth!
  • Bankruptcy, unlike IVAs and DMPs, are a catalyst for change – you are likely to live your life differently and ditch any bad habits in a bankruptcy;

Come back here next week for golden rule number 2!