Loan Recall Case Study: Amanda

“It’s as blatant a mis-sale as it gets”

The financial arrangement has followed her through letters, demands, and changes of company. It has affected her health and left her with something she calls “letterbox anxiety”: the physical jolt she feels when she hears post landing on the doormat.

Yet the story began remarkably ordinarily.

In the summer of 2016, Amanda secured a contracting role at Hiscox in London. She had been interviewed for the job, and negotiated a £160 daily rate. She understood the bargain in conventional terms: she would do the work and be paid for it.

She was new to contracting and was told she needed an umbrella company to process her earnings.  Within weeks, however, she was questioning what was happening to her money. By 2017, she was being told that £3,459.76 of the money she had received was an outstanding loan.

Today, West 28th Street Limited says it is the current lender in respect of a series of loans arising from those eight weeks of work.

Amanda says she has never seen the Master Loan Agreement under which those loans were supposedly made.

Her accountant, Nuala McLaughlin, spotted the underlying absurdity as far back as December 2017. Her question remains a remarkably good starting point: “How on earth is someone’s salary considered a loan?”

ContractorUK has now attempted to answer it.

What emerges from Amanda’s surviving paperwork is a trail involving an umbrella company, an employer, an employee benefit trust, an Isle of Man trustee, a loan-protection proposal, Felicitas Solutions, multiple assignments and, ultimately, West 28th Street.

We also showed the documents to a source with first-hand knowledge of contractor loan arrangements.

Their conclusion was stark. “It’s as blatant a mis-sale as it gets.”

Amanda wasn’t looking for a tax scheme

The surviving documentation indicates that Amanda had already obtained the Hiscox role before the payment structure was put around her.

A commercial agreement supplied to ContractorUK is between Hiscox Underwriting Group Services Ltd and Umbrella Requirements Ltd. Its schedule identifies Amanda as the individual providing the services, commencing on 25 July 2016 at Hiscox’s Bevis Marks offices in London.

In other words, at the top of this increasingly complicated chain is something extremely simple: Amanda went to work.

But the company with which Hiscox contracted was not the company that subsequently employed her.

On 18 July 2016, Adam Parker of IQ Contractors emailed Amanda, telling her that Umbrella Requirements would contact her before speaking to her agency. He added an intriguing instruction: “Please remember to only mention Umbrella Requirements to your agency.”

Parker explained that the agency would work only with an umbrella company or limited company. Three days later, however, it was IQ Contractors asking Amanda to accept an employment contract.

There was apparently a problem with IQ’s electronic acceptance system. Parker told Amanda the online “accept button” was not working and asked her instead to confirm by email that she accepted the contract, with the online process to be repeated later.

Ten years later, that apparently mundane technical problem has assumed rather greater significance. Because one of the central documents now missing from Amanda’s records is not merely an employment contract.

It is the alleged Master Loan Agreement.

Hiscox → Umbrella Requirements → IQ

Part of the contractual chain can be reconstructed. Hiscox’s commercial agreement is with Umbrella Requirements. Amanda is expressly identified as the person doing the work. Separately, IQ’s employment contract identifies Amanda as its employee and Umbrella Requirements as the client.

On the documents ContractorUK has seen, the working relationship therefore appears to run:

Her IQ employment contract defines her “Pay Rate” by reference to the minimum permissible under National Minimum Wage legislation. The remainder of her remuneration was dealt with differently.

Amanda’s reconstruction of the payslips shows a weekly expected value of £750, with £240.30 appearing as one payment and £423.70 described as a loan. Her accountant subsequently calculated the unexplained weekly deduction differently, at £136, so the surviving material does not yet allow ContractorUK to state a definitive figure for the difference.

But IQ’s own correspondence provides an important clue. Parker told Amanda: “You will always receive the 83% of whatever time you log on your timesheet.”

The remaining 17%, he said, covered umbrella fees, IQ’s fees, insurance, tax and National Insurance. In the same correspondence, however, he told Amanda that no tax had yet been deducted.

Amanda started asking questions. Her contention in 2026 that she did not understand what was happening is not a recollection reconstructed after the event. The emails show her questioning the arrangement in 2016.

When did Amanda’s earnings become a loan?

By the following year, the language had changed. Previse Consultants contacted Amanda about what it described as her former “loan-based arrangement” with IQ.

According to Previse, £3,459.76 remained outstanding. Its correspondence referred to a Master Loan Agreement. Amanda was baffled.

She understood the money appearing as a loan on her payslip to have formed part of the remuneration for the work she had actually performed at Hiscox.

So she asked Previse: “Can you please confirm whether IQ Contracts are saying that I owe them the funds that they had already claimed from HISCOX?”

Then her accountant intervened. McLaughlin asked how tax and National Insurance could be deducted from a loan, questioned the £136 per week she understood had been deducted during Amanda’s Hiscox contract, and said that when preparing Amanda’s tax return she had attempted to obtain information from IQ but had been“met with a brick wall.”

She asked Previse for “total clarity” about why it was seeking more money from Amanda. That exchange took place on 7 December 2017.

Amanda and her accountant were therefore challenging the characterisation of her earnings as a loan years before West 28th appeared in the story — and long before Amanda contacted ContractorUK.

Pay £69.20 — and protect yourself against a £3,459 debt?

There was another curious element to the Previse correspondence. Amanda was offered what was called “Loan Protection.”

For £69.20 plus VAT, she could apparently participate in an arrangement involving Pemberwick Limited under which her obligation to repay would be assumed if IQ subsequently demanded repayment.

The source who reviewed Amanda’s papers for ContractorUK was struck by this.

They compared it with borrowing £5,000 from a bank to buy a car and subsequently being offered a mechanism whereby a payment of around £100 could remove the obligation to repay the £5,000. They said the proposal raised a separate question about the nature of the underlying obligation and potentially moved the arrangement towards “sham territory.”

If £3,459.76 represented money genuinely advanced to Amanda under an enforceable obligation to repay it, how could £69.20 plus VAT apparently protect her from having to do so?

“The big one is obviously the loan agreement itself”

We asked our source what Amanda now needs most. They did not hesitate.

“The big one is obviously the loan agreement itself, which she doesn’t seem to have any record of,” our source said.

Amanda is more categorical. She says she did not simply lose or mislay a loan agreement: no loan agreement was ever presented to her, and she never knowingly agreed to borrow the money.

“Having negotiated £160 per day from Hiscox — which is evidenced in the Hiscox/Umbrella Requirements contract — I would never have signed for my salary to be paid at minimum wage with the rest as a loan,” she told ContractorUK.

ContractorUK has reviewed the IQ employment contract that Amanda retained. It contains employment terms and an assignment schedule, but it does not contain the Master Loan Agreement subsequently referred to by Previse. The copy reviewed by ContractorUK also does not appear to contain Amanda’s signature.

Amanda says that if West 28th, Felicitas, IQ or any other entity in the chain can now produce a loan agreement bearing her signature, it will be the first time she has seen it..

The source was particularly concerned about opacity in arrangements of this kind. In their experience of loan agreements, somebody entering one received a document clearly marked “loan agreement.”

They criticised practices that disguised a loan agreement by calling it something else, or buried it within employment documentation.

Amanda’s paperwork, they said, contained elements of unnecessary convolution which would make it difficult for somebody without specialist knowledge to understand what they had entered.

Their conclusion was simple: “People don’t know exactly what it is that they’ve been signed up to and involved with. And that’s wrong, to my mind.”

In 2026, when Trethowans referred to a Master Credit Agreement, Amanda asked for it:

“You refer to a Master Credit Agreement that I have no record of ever signing or seeing such a document. If you believe it exists, please send me a copy.”

That request goes to the heart of this story.

Why was this sold to Amanda in the first place?

Amanda’s annualised gross contract value was approximately £39,000. The higher-rate income-tax threshold at the time was £43,000. She wasn’t even a higher-rate taxpayer.

And by the time Amanda entered the arrangement, the government had already announced its attack on disguised-remuneration loans.

On 16 March 2016, the government announced measures aimed at employer-loan arrangements and what subsequently became the Loan Charge. Amanda entered the IQ arrangement several months later.

Our source described the position by then as: “the writing was on the wall.”

Their view is that responsible marketing of such arrangements should have been confined to sophisticated, high-earning users with an appetite for tax-planning risk and an understanding of the threat already announced.

Of Amanda, they said: “We’ve got a lady here whose income didn’t even get to the higher rate threshold.”

If arrangements were being sold to people in that position, they said, there could potentially be “an awful lot of people” who should never have been placed into them.

All this for £18 a week?

Our source reconstructed the economics from the documentation available.

Amanda’s annualised gross contract value was around £39,000. They calculated that fees associated with the arrangement appear to have been approximately £136 a week — around 18% of gross contract value, or £7,072 annualised.

They then compared the apparent outcome with conventional PAYE and National Insurance. Their estimate of Amanda’s immediate annualised improvement in take-home pay was approximately £928.

That is roughly £18 a week.

Because Amanda actually used the arrangement only briefly, the benefit she personally obtained would have been much smaller.

In exchange, she entered an arrangement exposing her to precisely the kind of future tax consequences the government had already announced.

Once that Loan Charge exposure is incorporated, our source calculated that Amanda was materially worse off than if she had simply been conventionally employed and taxed through PAYE.

“In these circumstances it is difficult to see how the sale could be justified in this case. It’s as blatant a mis-sale as it gets.”

And they described the economics of selling such an arrangement to someone in Amanda’s circumstances as: “Commercially, morally not defensible.”

Then the loan started travelling

On 5 February 2020, Amanda received a notice from ECS International Trustees (Isle of Man) Limited, acting as trustee of the IQ Contractors (UK) Employee Benefit Trust.

It said that under a Deed of Assignment dated 10 January 2020, the assignor’s: “entire right, title and interest” in Amanda’s outstanding loan had been assigned to Felicitas Solutions Limited.

Felicitas sent Amanda its own Notice of Acquisition of Lender’s Rights, identifying a debt of £3,459.76 and stating that it was now the lender.

Then, in 2026, the name changed again. Trethowans wrote to Amanda on behalf of West 28th Street Limited.

Its letter said: “West 28th is the current lender of the loans described in the enclosed statements, having acquired these loans by assignment from Felicitas Solutions Limited, the previous Assignee of the loan book.”

The letter says Amanda’s case comprises nine loans, with the first dated 12 August 2016 and the last 7 October 2016. The corrective statements themselves describe individual advances made during those weeks under a Master Credit Agreement dated “on or around 12 August 2016.”

So, on the documents presently available, the asserted journey looks like this:

But a chain of company names is not the same thing as proving each legal step in a chain of title. And Amanda still does not have the agreement at the beginning of it.

The 2026 letters contain another important admission

The West 28th statements are described as “Corrective Annual Statements” under section 77A of the Consumer Credit Act 1974. They acknowledge that West 28th and/or its predecessors had previously failed to send compliant annual statements. As a result, the statements say that contractual interest which would otherwise have accrued from September 2017 until the corrective statement was issued has been removed.

Trethowans’ covering letter goes further. It expressly says: “This letter is not a demand for payment.”

It states that during the identified period of non-compliance, no sum was payable and the agreement was not enforceable against Amanda during that period.

That does not itself establish that the principal sum has ceased to exist. But it demonstrates something important about this ten-year saga: even the current creditor acknowledges that statutory requirements governing the agreements were not complied with for a substantial period.

FOLLOW THE PAPER TRAIL: Where does Umbrella Requirements fit?

One company appears very early in Amanda’s story but disappears from the later loan-recovery correspondence: Umbrella Requirements Ltd.

Companies House records show the company filing accounts covering the period in which Amanda worked through the arrangement. Later accounts describe its principal activity as “employment placement agency and business support services” and identify Helen Little as director. The same name continues through subsequent filings.

And Umbrella Requirements did not disappear after 2016. According to the research assembled for this article, its accounts at 5 April 2024 reported £250,136 in debtors and £73,718 cash at bank and in hand, alongside £408,539 of creditors falling due within one year.

Those figures do not establish that any of those assets or liabilities relate to Amanda, IQ or the loan arrangements. Nor does the appearance of a company or individual in this corporate trail imply wrongdoing. But Umbrella Requirements matter for a different reason. It is the company sitting between Amanda’s Hiscox engagement and IQ in the surviving contractual documentation.

ContractorUK invites Umbrella Requirements and Helen Little to help us complete that part of the paper trail.

Can West 28th complete Amanda’s paper trail?

ContractorUK has reconstructed much of Amanda’s journey from a job at Hiscox in July 2016 to correspondence from West 28th Street and its solicitors in April 2026.

But important pieces are still missing. If West 28th holds them, we would like to see them.

In particular, ContractorUK invites West 28th Street to provide:

1. The Master Loan/Master Credit Agreement referred to repeatedly in the correspondence, which Amanda says she has never seen or possessed.
2. Evidence of Amanda’s agreement to enter a loan arrangement, including how and when the agreement was executed.
3. The documentation explaining the nine individual advances, and their relationship to the remuneration Amanda earned for her Hiscox work.
4. The complete documentary chain of assignment showing how the rights asserted against Amanda passed from the original lender/trust structure through Felicitas and ultimately to West 28th Street.
5. An explanation of the £69.20 Loan Protection proposal and how payment of that sum could apparently protect Amanda against repayment of a claimed £3,459.76 liability.
6. West 28th’s response to the mis-selling analysis produced by the industry source who examined Amanda’s papers for ContractorUK.

West 28th Street is invited to contact ContractorUK, provide the missing documents, and explain its position. We will publish any substantive response.

ContractorUK contacted Helen Little, Umbrella Requirements, Felicitas and Hiscox prior to publication of this article.

Appendix 1. Amanda’s actual loan timeline

THE “AMANDA” TOOLKIT

1. Start with you — not the loan company

Write down what your circumstances were when you entered the arrangement, not simply what they are now.

How old were you? What was your job? How much were you earning? Were you a higher-rate taxpayer? Were you an experienced contractor or new to contracting? Had you previously used tax-planning arrangements? Did you understand yourself to be seeking a tax scheme, or were you simply looking for an umbrella/payroll company so you could be paid for work you had already obtained?

Also record any relevant circumstances that may have affected your ability to understand or evaluate what was being offered. These might include illness, disability, bereavement, caring responsibilities, pregnancy, relationship breakdown, financial difficulty or other significant pressures.

The point is not that somebody experiencing difficulty cannot enter a contract. It is to reconstruct whether this was an appropriate product for the person to whom it was being sold, what information they were given, and whether they were realistically in a position to understand the risks.

2. Were you actually looking for a tax scheme?

This may be one of the most important distinctions.

Find the first emails, adverts or referrals that led you to the provider.

Ask:

• Who introduced me?
• What did I ask them for?
• What did they say they were providing?
• Did anybody tell me this was tax planning?
• Did anybody discuss the risks?
• Did I already have the contract/job before I was introduced to the scheme?

Keep emails showing how you entered the arrangement.

3. Find the loan agreement

Search old emails, cloud storage, paper files and attachments for anything called:

• Loan Agreement
• Master Loan Agreement
• Master Credit Agreement
• Credit Agreement
• Loan Advance
• Loan Application
• Loan Facility

Be precise. If you remember signing a loan agreement but have lost it, say that. If you simply cannot find one, say that. But if your recollection is that you were never presented with a loan agreement and never knowingly agreed to borrow the money, record that accurately too. Do not adopt the current claimant’s description of events if it does not reflect what you remember happening.

4. Does it actually say “Loan Agreement”?

If you do have a document, look at it as though you had never seen it before.

Is it conspicuously identified as a loan or credit agreement?

Or is the supposed loan contained within, linked from or incorporated into an employment contract, employee handbook, trust documentation or another document?

Were you asked to sign it separately?

Could an ordinary person reasonably have understood from the document that they were borrowing money which could later be demanded back?

5. What did you understand the money to be?

Go back to your payslips and bank statements.

For every payment, try to record:

Work performed → amount invoiced/expected → salary payment → “loan” payment → fees/deductions → amount received.

Then ask the most basic question:

At the time, did I understand this money to be borrowing — or did I understand it to be payment for my work?

6. Work out what financial benefit you actually received

Don’t simply accept claims that the scheme saved you tax.

Try to establish:

• What were the scheme fees?
• What percentage of your gross earnings was retained?
• What would conventional PAYE have cost?
• What extra take-home pay did the arrangement actually produce?
• What additional tax liability or Loan Charge exposure did it create?

If necessary, ask an independent accountant to reconstruct it.

7. What risks had already been announced when you joined?

Record the exact dates you entered and left the arrangement.

Don’t just ask what the rules are today. Ask:

• What had HMRC or the government already announced at that point?
• What risks should the provider have known about?
• Were those risks explained to me?

8. Was there a “loan protection”, write-off or similar offer?

Search for later correspondence offering insurance, protection, settlement, novation, transfer or cancellation of the supposed loan.

Record:

• how much the alleged debt was;
• how much you were being asked to pay;
• what supposedly happened to the debt afterwards;
• which company made the offer?

Keep the documents and ask what the arrangement actually did legally.

9. Did your loan travel through the Isle of Man?

Look through all the paperwork, not just the latest demand.

Check for:

• Isle of Man / IOM
• Douglas
• .im email or web addresses
• Manx trustees
• assignment notices
• loan administrators
• EBT trustees

Then build a simple timeline:

Original lender → trustee → subsequent owner → administrator → current claimant

An Isle of Man connection does not by itself mean a loan is invalid or unenforceable. It tells you another part of the lifecycle needs to be documented.

10. Can the current claimant prove how it acquired your particular loan?

Depending on your circumstances, the questions may include:

• Who was the original lender?
• Who held the loan next?
• When was it assigned?
• What was actually transferred?
• Does the assignment include my individual loan?
• Who is asserting ownership now?

11. Check for corrective statements or admitted non-compliance

Does it mention:

• Consumer Credit Act 1974
• section 77A
• Corrective annual statements
• periods of unenforceability
• interest being removed
• failure to provide previous statements?

Keep those documents.

12. Record what the chasing is doing to you now

This should be evidence, not embellishment.

Keep a private chronology of the effects correspondence has on your health and daily life.

Examples might include:

• anxiety when post or email arrives;
• sleep disturbance;
• raised blood pressure;
• panic symptoms;
• GP appointments or medication;
• difficulty working;
• financial decisions made because of fear of the alleged debt;
• effects on relationships or family life.

If you have medical evidence, keep it.

13. Separate the two periods of vulnerability

THEN: What circumstances affected your understanding or suitability when the arrangement was sold?

NOW: What effect is pursuit of the alleged debt having on you today?

Record both accurately.

14. Assemble your “Amanda file”

• original job/agency correspondence;
• umbrella/provider introduction;
• employment contract;
• every loan/credit agreement you possess;
• payslips;
• bank statements showing relevant payments;
• timesheets/rate evidence;
• emails where you questioned deductions or the arrangement;
• tax returns/accountant correspondence;
• Loan Protection/write-off/settlement offers;
• notices of assignment;
• Isle of Man correspondence;
• Felicitas correspondence;
• current creditor/solicitor correspondence;
• corrective annual statements;
• relevant medical or hardship evidence;
• one-page chronology of dates, entities and amounts.

Then don’t send the originals anywhere.

15. Ask the current claimant clear questions

Please provide the agreement under which you say I borrowed this money.

Please provide evidence showing when and how I agreed to that loan arrangement.

Please identify the original lender and provide the documentary chain by which you say the rights under my individual agreement passed to you.

Please explain the relationship between the alleged loan advances and the remuneration generated by my work.

Please identify any periods during which the agreement was not enforceable or statutory statements were not supplied.

Please address my contention that the arrangement was not properly explained and was unsuitable for my circumstances when it was sold.

Are you an “Amanda”?

You don’t have to match Amanda in every respect. But tell ContractorUK if several of these sound familiar:

• You were relatively modestly paid.
• You were new to contracting.
• You already had the job and simply needed a way to be paid.
• You did not knowingly go looking for sophisticated tax planning.
• You understood the “loan” money to be part of your remuneration.
• You questioned the arrangement at the time.
• You cannot find a clearly labelled loan agreement.
• Your alleged loan subsequently passed through several companies or jurisdictions.
• An Isle of Man entity appears in the chain.
• You are now being pursued years later by a company you had never heard of when you did the work.
• And the continuing correspondence is affecting your health or wellbeing.

If that sounds like your case, preserve the paperwork. Build the timeline. Find the agreement — or ask the claimant to produce it. And tell us what your documents show.