Mondaq Business Briefing articles from February 2009

Mondaq Business Briefing archives from February 2009

USCIS Revises I-9 Employment Eligibility Verification Form.(Brief article)
February 1, 2009... December 17, 2008 – The U.S. Citizenship and Immigration Services (USCIS) published a new rule updating the list of acceptable documents for the Form I-9 Employment Eligibility Verification process, along with changes to Form I-9 itself....

Bankruptcy Court Approves Sale Of Title Insurance Companies.
February 1, 2009... On Wednesday, December 17, 2008, the United States Bankruptcy Court for the Eastern District of Virginia approved the sale by LandAmerica Financial Group, Inc. of all of the issued and outstanding stock of Commonwealth Land Title Insurance...

ABI Guidance On Share Allotment Authorities, BERR Consultation On Notice Periods For Meetings, FSA Clarifies Disclosure Requirements.(Association of British Insurers )
February 1, 2009... New ABI Guidance on Authorities to Allot Shares The Association of British Insurers (ABI) has recently issued new guidance on the extent of the general allotment authority (under s.80, Companies Act 1985) which it regards as acceptable for...

Injunction Of RIM's Bid For Certicom Necessitates Careful Review Of Confidentiality Agreements.(Ceritcom Corp. v. Research in Motion Limited )(Case overview)
February 1, 2009... The Ontario Superior Court of Justice's decision this week in Ceritcom Corp. v. Research in Motion Limited et al. has significant implications for M&A practice in Canada, particularly in hostile situations. In Certicom, the court issued an...

Court Upholds Internal Investigation Privilege.
February 1, 2009... HMTQ v. Canadian National Railway Company 2008 BCSC 1677 The Supreme Court of British Columbia recently upheld a claim for common law litigation privilege asserted by Canadian National Railway Company (CN) over documents created in the...

OSC Orders HudBay Shareholder Vote In Lundin Merger.(Ontario Securities Commission)(Lundin Mining Corp. acquired with HudBay Minerals Inc.)
February 2, 2009... On January 23, 2009, the Ontario Securities Commission prohibited HudBay Minerals Inc. (HudBay) from issuing shares in connection with its proposed merger with Lundin Mining Corporation (Lundin) without first obtaining HudBay shareholder...

Statutory Disciplinary And Grievance Procedures - The End?
February 2, 2009... On 6 April 2009, the Statutory Disciplinary and Grievance Procedures will be abolished. They will be replaced by a new ACAS Code of Practice on Disciplinary and Grievance Procedures (the "New Code"). This is not to be confused with the current...

Divisional Court Curtails Moe Investigation Powers.
February 2, 2009... Article by *Doug Petrie and *Juli Abouchar On January 7, 2009, the Divisional Court of the Ontario Superior Court of Justice released a decision (Branch) that will significantly affect how Ontario's Ministry of the Environment (MOE)...

Floating On The IEX.
February 2, 2009... A company can raise capital in a number of ways; for example, by private offers of shares for subscription, by borrowing or by using retained profits. Another way a company can raise capital is by way of public offers of shares on a stock...

Jones Day And ECTA Publish European Regulatory Scorecard For 2008.
February 2, 2009... On January 28, 2009, the European Competitive Telecommunications Association (ECTA) published the 2008 Regulatory Scorecard. This is the sixth issue of its annual benchmark report on the effectiveness of telecommunications regulation across...

New Maternity, Paternity And Parental Leave Entitlements.
February 2, 2009... On 1 January 2009, standard maternity leave entitlement increased from 18 to 20 weeks, with longer for multiple births. The new entitlement applies to all employees on maternity leave at 1 January 2009, as well as those whose maternity...

PAYE: Pitfalls On The Exercise Of Employee Share Options.
February 2, 2009... The recent case of Chilcott, Griffiths and Evolution Group Services v Revenue & Customs has highlighted a pitfall for employers and employees where PAYE is not properly operated on the exercise of employee share options or other share-related...

First Bill President Obama Signs Makes it Easier for Employees to Allege Discrimination in Compensation.
February 2, 2009... Originally published January 29, 2009 Keywords: Lilly Ledbetter Fair Pay Act, statute of limitations, EEOC, compensation discrimination, Title VII, ADA, Rehabilitation Act, ADEA, disparate impact claims On January 29, 2009, President...

Lilly Ledbetter Fair Pay Act Becomes Law.
February 2, 2009... On Thursday, January 29, 2009, President Obama signed into law the Lilly Ledbetter Fair Pay Act ("Ledbetter Act"), the first new statute he has signed. The Ledbetter Act amends Title VII of the 1964 Civil Rights Act and the Age Discrimination...

Responding To Allocation And Liquidity Concerns Of Investors In Private Equity And Venture Capital Funds.
February 2, 2009... Article by Jonathan Axelrad , Matthew L. Giles , Kenneth J. Gordon , Rufus C. King and David W. Watson Recent economic events have raised a host of allocation and liquidity issues for investors in private equity and venture capital...

Wisconsin Supreme Court Rules That Each Asbestos Claimant's Exposure Constitutes A Separate Occurrence; Adopts "All Sums" And Rejects Pro Rata Allocation.
February 2, 2009... Wisconsin's highest court is the latest to weigh in on the obligations of liability insurers for underlying asbestos bodily injury claims. In Plastics Engineering Co. v. Liberty Mutual Insurance Co., No. 2008AP333-CQ (Wis. Jan. 29, 2009), the...

New I-9 Form Required Starting February 2nd, 2009.
February 2, 2009... Starting on February 2nd, 2009, employers will have to use the new I-9 Employment Verification form (edition date February 2, 2009). On that date, employers must use the revised I-9 form and instructions for all new hires. There is no...

Global Companies Faced With An Increasing Role Of The European Works Council.
February 2, 2009... After four years of discussions and negotiation between the European labor and management stakeholders, the EU Parliament adopted an agreement on a revised European Works Council Directive, aimed at improving the role of the European Works...

Motor Vehicle Dealers Act Coming Into Effect April 1, 2009 Equipment Financiers Must Take Action.(Brief article)
February 2, 2009... On April 1, 2009, the long awaited Motor Vehicle Dealers Act, 2002 ("Act") is anticipated to come into force. This Act will have a broad impact to all motor vehicle dealers, the equipment finance community and sellers of extended warranties....

New York Mini-WARN Law Requires 90-Day Advance Written Notice Of Certain Employee Layoffs.
February 2, 2009... Article by Albert J. Solecki, Jr. , Eric D. Roth and Daniel J. Doron The economic downturn that, in late 2008, dealt a sharp blow to many New York employers has led many of those employers to consider reductions in force. Indeed, the...

Massachusetts Life Sciences Center Launches New Tax Incentive And Early-Stage Investment Programs.
February 2, 2009... The Massachusetts Life Sciences Center (the "MLSC"), a quasi-public agency tasked with implementing the State's $1 billion Life Sciences Initiative, is now accepting online applications for its Life Sciences Tax Incentive Program and its Life...

Cotton On Caught Copying.
February 2, 2009... Key Points: Elwood Clothing t-shirt and swing tag designs are held to be artistic works by the Full Federal Court and protectable pursuant to copyright law. Designs admittedly copied by Cotton On have been found by the Full Federal...

Fair Work Bill 2008.
February 2, 2009... Contents Transfer of business Extension of union officials' right of entry under the Fair Work Bill 2008 Transfer of business The Fair Work Bill 2008 (Cth) introduces significant changes to the transmission of business laws...

VaR Limit Clarification.
February 2, 2009... Introduction On 29th October, 2008, the Financial Regulator published a short paper1 and revised Guidance Note 3/03 providing for a clarification of the limits to be applied by a UCITS when calculating global exposure using the absolute...

Opportunities For Property Tax Refunds.(Brief article)
February 2, 2009... Property owners are aware of the significantly increased assessments that have been returned for the 2009 taxation year. Our previous Advisory reported on the 2009 assessments and provided information on how to appeal. In addition to the...

Electronic Health Records: The Time For Implementation Is Now.
February 2, 2009... President Obama has allocated money from his recently proposed economic stimulus package to investment in healthcare IT, but will it be enough for the United States to implement an integrated, nationwide health information network? With efforts...

Anticipated Policy Changes For Embryonic Stem Cell Research: Funding Under The Obama Administration.
February 2, 2009... Soon after the November 2008 election, then-President-elect Obama signaled his intention to issue executive orders to repeal decisions made by the Bush administration on diverse policies, including the limitations imposed on embryonic stem cell...

Shake-Up Coming For Canadian Private Placement Regime?
February 2, 2009... In response to the seizure of the market for asset-backed commercial paper (ABCP) in Canada, the Canadian Securities Administrators formed a working group to consider certain regulatory issues arising out of this seizure. The working group...

2009 Budget Highlights - Extraordinary Times Calling For Extraordinary Global Measures.
February 2, 2009... On January 27, 2009, the Honourable Jim Flaherty, Minister of Finance, tabled the 2009 federal budget titled "Canada's Economic Action Plan". The nature and purpose of the Action Plan can be summarized by a statement in the Overview of the...

Maintaining a Shelf Registration Statement Following Loss of WKSI Status.(well-known seasoned issuer)
February 2, 2009... Originally published January 30, 2009 Keywords: shelf registration statement, WKSI, sell securities, filing fees, pay-as-you-go, Securities Act, time of filing, stock prices, compliance, disclosure, A registrant that qualifies as a...

Sovereign Immunity.(Brief article)
February 2, 2009... An ambassador's certificate which confirmed that certain London bank accounts of Chad were not used for commercial purposes failed to impress the Commercial Court. In Orascom Telecom v Chad [2008] EWHC 1841, the court decided that the...

European Insolvency And Pending Arbitration.(Brief article)
February 2, 2009... In Syska v Vivendi [2008] EWHC 2155, the Commercial Court had to consider the effect of a Polish company's insolvency on pending LCIA arbitration in London, in which it was a party. The arbitration proceedings had been brought against the...

Ontario Begins Consultative Process For Design Of Greenhouse Gas Cap-And-Trade System.
February 3, 2009... The Ontario Government has begun consultations leading to the implementation of a greenhouse gas cap-and-trade system, which may be in place as early as 2010. Ontario had previously stated its intention to develop a greenhouse gas...

Defaulting Limited Partners: Challenges For Private Equity In 2009.
February 3, 2009... Introduction Liquidity concerns are all too familiar to most private equity fund managers these days, and investors in their funds have not been immune. However, at the time of writing, there have been few significant public defaults by...

Pre-Packaged Sales - New Guidance For Administrators.
February 3, 2009... Pre-packaged sales have long been regarded with suspicion by unsecured creditors. These are where a company is placed into administration and, almost simultaneously, its assets and business a sold by the Administrator without any prior...

Top Tax Tips For Troubled Times - Managing Corporation Tax.
February 3, 2009... Mark Webb offers some suggestions on how to effectively manage your company's corporation tax liabilities in a downturn. As the property industry is facing a particularly acute downturn, businesses will need to review and tighten processes....

A Restorative Relief - The Business Premises Renovation Allowance (BPRA).
February 3, 2009... BPRA should encourage developers to renovate or convert derelict property. The Business Premises Renovation Allowance (BPRA) was brought in to incentivise individuals and/or companies to bring certain properties back into use. BPRA...

Maritime Issues In The E & P Industry.
February 3, 2009... The development of the petroleum and natural gas industry in Brazil also made possible the expansion of the local maritime industry. The end of Petrobras' monopoly and the promotion of bid rounds by the Brazilian National Petroleum Agency (ANP)...

Auditors In The Spotlight.
February 3, 2009... This week's hearing between the Treasury Committee and representatives of the auditing profession questions the role of the auditor in the current economic crisis. The hearing reflects the fact that auditors are facing increasing difficulties...

Massive Cartel Fines For The Upstream Oil Sector.
February 3, 2009... Yesterday, the European Commission announced that it has imposed fines totalling over €131 million on five companies involved in the marine hoses cartel, which operated worldwide between 1986 and 2007. The cartel members, Bridgestone,...

FDA Issues Draft Guidance On Citizen's Petitions.(Food and Drug Administration )
February 3, 2009... On January 21, 2009, the Food and Drug Administration ("FDA") issued a draft guidance titled "Citizen Petitions and Petitions for Stay of Action Subject to Section 505(q) of the Federal Food, Drug, and Cosmetic Act," setting forth the FDA's...

The Expert Panel On Securities Regulation Delivers Final Report.(Canadian Securities Commission )
February 3, 2009... Final Report And Draft Legislation Released In February 2008, the Government of Canada established a third-party Expert Panel on Securities Regulation charged with providing the federal Minister of Finance and the provincial and territorial...

Update On New I-9 Form: Implementation Delayed To April 3, 2009.(Brief article)
February 3, 2009... The United States Citizenship and Immigration Services (USCIS) announced on January 30th that the implementation of the revised I-9 form has been delayed 60 days to April 3, 2009. The revised form (with edition date 02/02/09) was scheduled to...

E-Verify For Federal Contractors Now Postponed Until May 21, 2009.
February 3, 2009... On January 8, 2009, the federal government again agreed to postpone, until May 21, 2009, implementation of the executive order and related federal procurement law that require federal contractors and certain subcontractors to use E-Verify to...

Obama Signs Lilly Ledbetter Fair Pay Act.
February 3, 2009... President Obama has signed the Lilly Ledbetter Fair Pay Act (Act), which substantially eases restrictions on employees suing for wage discrimination. Overturning the U.S. Supreme Court's 2007 decision in Ledbetter v. GoodyearTire & Rubber...

US Investors In Australia Beware: New Advisory Report Supports The Sons Of Gwalia Decision.
February 3, 2009... We have previously reported on the infamous Sons of Gwalia decision in which the High (i.e. Supreme) Court of Australia concluded that a shareholder's claim against an Australian issuer for damages caused by defective disclosure practices...

While Markets Continue To Fall, Fraud Activity Continues To Rise.
February 3, 2009... While the global economy continues to fall, incidences of corporate fraud are on the rise. The current economic instability, coupled with weakened internal controls found in many organizations, both large and small, has created the perfect...

Proposal To Regulate Private Funds And Their Advisers Introduced In U.S. Senate.
February 3, 2009... Article by Elizabeth Shea Fries , Byron C. Pavano , Jonathan Axelrad , Satish M. Kini and Sean P. O'Malley On January 29, 2009, Senators Carl M. Levin (D-MI) and Charles E. Grassley (R-IA) introduced a bill titled the "Hedge Fund...

Allowance To Boost Business Investment.
February 3, 2009... As part of their broader economic stimulus package, on 12 December 2008 the Federal Government announced an investment allowance giving business taxpayers an additional 10% capital allowance deduction for new tangible assets. When does the...

CIVIL FALSE CLAIMS ACT: Recent Developments Increase Possibility Of FCA Claims Against Recipients Of TARP Funds And Contractors Retained By Treasury For TARP Services.(Federal Acquisition Regulation )(Law overview)
February 3, 2009... Effective tomorrow, December 12, 2008, government contractors must implement a new mandatory disclosure requirement under the Federal Acquisition Regulation ("FAR") that is triggered whenever they have "credible evidence" of a False Claims Act...

An Introduction To Jersey Foundations.(Law overview)
February 3, 2009... In 2009 Jersey will unveil its draft Foundations (Jersey) Law 200[ ] (the "Draft Law") and, although the introduction of the civil law concept of private foundations into a jurisdiction that has built its name and reputation around the common...

Bucking Historic Trends - Jersey, Cayman & BVI Funds.
February 3, 2009... Historic trends are frequently considered when comparing offshore jurisdictions, including for the purpose of choosing a fund domicile. Jersey, Cayman and BVI provide no exception. Theoretically, concentrations of offshore funds may be defined...

Cross Border Insolvency - Putting Jersey Companies Into English Administration?
February 3, 2009... Jersey has its own distinct insolvency procedures, the most important of which for companies are creditors winding up and desastre (bankruptcy). A creditors winding up is not instigated by creditors – it is the insolvent company which...

Land Tax Recovery Revisited - Queensland May Go 'Back Into Step' With Other States.
February 3, 2009... Recovery of land tax for commercial and industrial leases The Queensland Government has released a draft Bill to amend the Land Tax Act 1915 (LTA). If enacted, the changes will allow landlords of commercial and industrial properties to...

Google Library Project Settlement Agreement.
February 3, 2009... On 28 October 2008, the Authors Guild, the Association of American Publishers and Google announced that they had reached a potentially groundbreaking Settlement dealing with Google's much-publicised 'Library Project', which involved Google...

Canada's Budget 2009 - A Shade Of Green.
February 3, 2009... The increasingly anemic Canadian economy was administered a boost in the form of an unprecedented stimulus package announced in the federal government's Budget 2009 released on January 27, 2009. The budget contains a number of programmes and...

FCPA Settlements: It's A Small World After All.(Foreign Corrupt Practices Act of 1977)
February 3, 2009... "...that whole law started on the basis of my going home in the evening in the early '70s and watching the Watergate hearings. And watching at the end of the hearings where certain companies would testify as to making political contributions to...

Amendments To Canadian Corporate Governance And Audit Committee Regimes Proposed.
February 3, 2009... Copyright 2009, Blake, Cassels & Graydon LLP Originally published in Blakes Bulletin on Securities Regulation, January 2009 The Canadian Securities Administrators (the CSA) have published for comment proposed revisions to the existing...

CSA Provides Guidance On Continuous Disclosure Obligations Related To Current Economic Conditions.
February 3, 2009... Copyright 2009, Blake, Cassels & Graydon LLP Originally published in Blakes Bulletin on Securities Regulation, January 2009 The global economic downturn of the past few months has led to increased scrutiny of public disclosure by...

Supreme Court Declares Ambiguous Non-Competition Clauses Unenforceable.
February 3, 2009... On January 23, 2009, the Supreme Court of Canada handed down a decision regarding the Court's role in interpreting and enforcing restrictive covenants. More specifically, the Supreme Court held that it is not for a Court to interpret or "fix"...

PRC Labour Contract Law Implementing Regulations Issued.
February 3, 2009... On 18 September 2008, the State Council promulgated implementing regulations ("Implementing Regulations") for the PRC Labour Contract Law, which has been in effect since 1 January 2008. These regulations address the following key aspects: ...

Alberta Court Of Appeal Finds Mistake In Dispute Over Unit Agreement.
February 3, 2009... Copyright 2009, Blake, Cassels & Graydon LLP Originally published in Blakes Bulletin on Litigation, January 2009 Introduction On December 22, 2008, the Alberta Court of Appeal released its decision in Signalta Resources Limited v....

National Association Of Insurance Commissioners Rejects Capital Changes For Life Insurers.
February 3, 2009... Article by Francine L. Semaya , William K. Broudy and Laurance D. Shapiro The National Association of Insurance Commissioners ("NAIC") has rejected changes in capital and surplus requirements for life insurers proposed by the American...

Significant Changes To Business Tax For Foreign Service Providers.
February 3, 2009... Changes to Levying Principle on Taxable Services Effective 1 January 2009, the levying principle of business tax ("BT") on services in the People's Republic of China ("PRC") has been changed from where the service is performed to where the...

New York Court Upholds Insurance Department's Decision That Trade Secrets Are Exempt From Foil Disclosure.
February 3, 2009... Article by Francine L. Semaya , William K. Broudy and Laurance D. Shapiro On January 13, 2009, the New York Supreme Court, the trial level court in New York, denied a challenge to the New York Insurance Department's (the "Department")...

The Value Of Infrastructure: 2009 Federal Budget.
February 3, 2009... Copyright 2009, Blake, Cassels & Graydon LLP Originally published in Blakes Bulletin on Infrastructure, January 2009 On January 27, 2009, Finance Minister Jim Flaherty tabled Canada's Economic Action Plan, the federal government's 2009...

Hunt Succeeds Before Energy Resources Conservation Board In Competitive Drainage Case.(Hunt Oil Company of Canada Inc.)
February 3, 2009... Copyright 2009, Blake, Cassels & Graydon LLP Originally published in Blakes Bulletin on Energy, January 2009 Introduction On December 23, 2008, the Energy Resources Conservation Board (the ERCB) issued its decision in an...

Corporate Governance - Board Meetings And Minutes.
February 3, 2009... Generally the powers of a company are exercised by the board of directors acting as a whole, subject to its articles of association. Usually those powers can only be exercised collectively by resolution at properly constituted board meetings or...

Duty Act Changes.(Brief article)
February 3, 2009... The time for payment of duty under the Duties Act 2008 will shortly be reduced. At present duty must be paid not later than 3 months after the liability date. That period will be reduced from 3 months down to 14 days. This means, for example,...

Further International Recognition For Cains.
February 3, 2009... Cains, one of the leading Isle of Man law firms, has been shortlisted for another prestigious industry award. The firm has been nominated for the Offshore Category of the 2009 Chambers Europe Awards for Excellence. The results will be announced...

New Illinois Campaign Contribution and Registration Requirements May Affect Investment Funds and Managers.
February 3, 2009... Originally published January 30, 2009 Keywords: Illinois, campaign contribution, registration requirements, investment funds, investment managers, new ethics law, covered entities, state contracts, executive order Two new procurement...

IRS Initiates Compliance Check on Governmental Bond Financings.
February 3, 2009... Article by John A. Janicik , David Narefsky , Joanna K. Horsnail and Lorraine M. Tyson Originally published February 2, 2009 Keywords: IRS, compliance check, governmental bond financings, Tax Exempt Bond Office, TEB, tax-exempt...

New York Insurance Department Issues Opinion On Treatment Of Collateral Held By An Insurer In Liquidation Or Rehabilitation.
February 3, 2009... Article by Francine L. Semaya , William K. Broudy and Laurance D. Shapiro Certain insurance programs, particularly workers' compensation programs with large deductibles, require the insured to deposit collateral with the insurer as...

Bill 139 - New Rights For Temporary Workers.
February 4, 2009... Last month, the Ontario Government introduced Bill 139, the Employment Standards Amendment Act (Temporary Help Agencies), 2008 (the "Bill"). The proposed legislation is part of the Government's Poverty Reduction initiative designed to aid low...

Choosing the Right Remedies to Enforce Security.
February 4, 2009... In the period immediately following a default by a borrower, a mortgage lender is often faced with a number of strategic issues to consider. The lender must quickly determine, among other things, the underlying cause(s) of the default, whether...

Privacy Law Development: Issuance Of Guidelines Regarding The Collection Of Driver's Licence Numbers.
February 4, 2009... The use of driver's licences to verify the identity of customers and to deter and detect fraud has come under special scrutiny by the Privacy Commissioners of Canada, Alberta and British Columbia. While addressed specifically to the retail...

Renewals vs. Extensions Of Lease Terms.
February 4, 2009... As commercial tenants do not have a default legal entitlement to renew or extend an existing lease, a common element of many leases is a right in favour of the tenant to continue its occupancy beyond the expiry of the current term. While the...

New Directions In Antitrust Enforcement: Obama Appoints Christine Varney To Head DOJ Antitrust Division.(Department of Justice. Antitrust Division)
February 4, 2009... During the presidential campaign, now-President Obama vowed to "reinvigorate antitrust enforcement."1 He sharply criticized the Bush administration as having the "weakest record of antitrust enforcement of any administration in the last half...

Work Product Doctrine Vindicated In "Textron".(Textron, Inc.)
February 4, 2009... On January 21, the Court of Appeals for the First Circuit, in a 2-1 decision, affirmed in part and remanded in part the decision of the trial court in United States v. Textron, 507 F. Supp. 2d 138 (D.R.I. 2007). In a vigorous and thorough...

New Client Identification And Verification Requirements: How They Will Affect You.(Law overview)
February 4, 2009... On December 31, 2008, the Law Society of Upper Canada (the body which regulates lawyers practicing in Ontario) enacted new rules aimed at preventing inadvertent money laundering and terrorist financing through lawyers' trust accounts. These...

Arbitration In Liechtenstein - Its Significance In Liechtenstein Law.
February 4, 2009... GENERAL In Liechtenstein law and especially in the social system, arbitration has achieved a position of considerable significance. One of the reasons for this is the discretion which is associated with arbitration proceedings since these...

The Supreme Court Releases Reasons In The BCE Litigation.
February 4, 2009... The Background In late-December 2008, the Supreme Court of Canada (the "Court" or the "SCC") released the written reasons for its decision earlier in the year to approve the plan of arrangement by which the proposed acquisition of BCE Inc....

Weekly Climate Change Policy Update - February 2, 2009.
February 4, 2009... Article by Kyle W. Danish, Shelley N. Fidler, Andrea Hudson Campbell, Kevin M. Gallagher and Megan Ceronsky To receive the Weekly Update via email, visit our Sign Up/Subscribe page http://www.vnf.com/news-signup.html Commentary: As...

Predictions For 2009: What Construction Insurers Need To Know Now.
February 4, 2009... 2009 could see some major legislative changes which will impact upon construction professionals and their insurers. This briefing looks into the crystal ball, and sees what the year may hold... 1. The Credit Crunch Bites While some...