{"id":410,"date":"2020-04-10T09:49:35","date_gmt":"2020-04-10T09:49:35","guid":{"rendered":"http:\/\/thecompliancealliance.co.uk\/blog\/?p=410"},"modified":"2023-02-10T19:43:13","modified_gmt":"2023-02-10T19:43:13","slug":"measures-to-help-ips","status":"publish","type":"post","link":"https:\/\/thecompliancealliance.co.uk\/blog\/news\/measures-to-help-ips\/","title":{"rendered":"Welcome measures to help IPs in these times"},"content":{"rendered":"<p>In my last blog post, I published a wishlist of measures that would help IPs to do their jobs in these difficult times.\u00a0 Since then, some extraordinary steps have been taken very quickly to address many of them.\u00a0 Here, I summarise those actions.<\/p>\n<p><strong><u>Taking on New Appointments<\/u><\/strong><\/p>\n<ul>\n<li><strong>Notices of intention to appoint, and of appointment of, administrators: <\/strong>the Temporary Insolvency Practice Direction (<a href=\"http:\/\/www.judiciary.uk\/publications\/temporary-insolvency-practice-direction-approved-and-signed-by-the-lord-chancellor\/\">judiciary.uk\/publications\/temporary-insolvency-practice-direction-approved-and-signed-by-the-lord-chancellor\/<\/a>) came into force on 6 April. Although it states that a statutory declaration by video conference may constitute a formal defect or irregularity, it confirms that this by itself shall not be regarded as causing substantial injustice, provided that the declaration is carried out in the manner specified in the Practice Direction:<\/li>\n<\/ul>\n<p style=\"padding-left: 60px;\">\u201c9.2.1. The person making the statutory declaration does so by way of video conference with the person authorised to administer the oath;<\/p>\n<p style=\"padding-left: 60px;\">9.2.2 The person authorised to administer the oath attests that the statutory declaration was made in the manner referred to in 9.2.1 above; and<\/p>\n<p style=\"padding-left: 60px;\">9.2.3 The statutory declaration states that it was made in the manner referred to in paragraph 9.2.1 above.\u201d<\/p>\n<p style=\"padding-left: 40px;\"><em>UPDATE 31\/03\/2021: a new Temporary Insolvency Practice Direction (<a href=\"https:\/\/www.judiciary.uk\/publications\/extended-temporary-insolvency-practice-direction-approved-and-signed-by-lord-wolfson\/\">https:\/\/www.judiciary.uk\/publications\/extended-temporary-insolvency-practice-direction-approved-and-signed-by-lord-wolfson\/<\/a>) comes into force tomorrow, which keeps the above in place until 30 June 2021.<\/em><\/p>\n<p style=\"padding-left: 40px;\"><em>UPDATE 01\/07\/2021: a further Temporary Insolvency Practice Direction has been issued (<a href=\"https:\/\/www.judiciary.uk\/publications\/extended-temporary-insolvency-practice-direction-approved-and-signed-by-lord-wolfson-2\/\">https:\/\/www.judiciary.uk\/publications\/extended-temporary-insolvency-practice-direction-approved-and-signed-by-lord-wolfson-2\/<\/a>) extending the provisions to 30 September 2021.<\/em><\/p>\n<p style=\"padding-left: 40px;\"><em>UPDATE 12\/10\/2021: another TIPD has been issued (<a href=\"https:\/\/www.judiciary.uk\/guidance-and-resources\/temporary-insolvency-practice-direction\/\">https:\/\/www.judiciary.uk\/guidance-and-resources\/temporary-insolvency-practice-direction\/<\/a>).\u00a0 This Direction remains in force &#8220;unless amended or revoked by a further insolvency practice direction&#8221;.<\/em><\/p>\n<ul>\n<li>But does this process also work for <strong>MVL Declarations of Solvency<\/strong>? The Insolvency Service quickly expressed the view that \u201cthere is no reason to suspect that the courts would not take a similar approach for the swearing of any statutory declaration required for the purpose of an insolvency procedure, during the period the practice direction is in force\u201d (<a href=\"https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/some-clarity-on-mvl-swearing---and-the-temporary-insolvency-practice-direction-2020-effective-from-the-evening-of-3-april-2020\">https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/some-clarity-on-mvl-swearing&#8212;and-the-temporary-insolvency-practice-direction-2020-effective-from-the-evening-of-3-april-2020<\/a>).\u00a0 Companies House has also confirmed that it \u201cwill accept a Declaration of Solvency sworn via video\u201d (<a href=\"https:\/\/content.govdelivery.com\/accounts\/UKIS\/bulletins\/28580cf\">https:\/\/content.govdelivery.com\/accounts\/UKIS\/bulletins\/28580cf<\/a>).<\/li>\n<\/ul>\n<p style=\"padding-left: 60px;\"><em>UPDATE 30\/05\/2020: Please note that the authority for statutory declarations to be administered virtually in Scotland derives from Schedule 4 para 9 of the Coronavirus (Scotland) (No. 2) Act 2020 (<a href=\"http:\/\/www.legislation.gov.uk\/asp\/2020\/10\/enacted\">http:\/\/www.legislation.gov.uk\/asp\/2020\/10\/enacted<\/a>), which came into force on 27 May 2020.\u00a0 The provisions are temporary and have an expiry date of 30 September 2020, although this can be extended by regulations.\u00a0\u00a0UPDATE 27\/09\/2020: the expiry date has been extended to 31 March 2021 by means of the Coronavirus (Scotland) Acts (Amendment of Expiry Dates) Regulations 2020.\u00a0 UPDATE 31\/03\/2021: the expiry date has been extended again to 30 September 2021 by means of the Coronavirus (Scotland) Acts (Amendment of Expiry Dates) Regulations 2021.\u00a0 UPDATE 04\/09\/2021: the expiry date has been extended again to 31 March 2022 by means of the Coronavirus (Extension and Expiry) (Scotland) Act 2021.\u00a0 UPDATE 05\/04\/2022: the expiry date has been extended again to 30 September 2022 by means of the Coronavirus (Scotland) Acts (Amendment of Expiry Dates) Regulations 2022 and the Coronavirus (Recovery and Reform) Scotland Bill proposes to make the amendment permanent.\u00a0 UPDATE 05\/07\/22: the Coronavirus (Recovery and Reform) Scotland Bill was passed on 29 June 2022.\u00a0 It takes effect from 1 October 2022, making remote statutory declarations for Scottish processes permanent.<\/em><\/p>\n<ul>\n<li>There have been no regulatory measures to help directly with posting mailouts, but many IPs have been exploring outsourcing options. Although I\u2019m sure there are many providers, I understand that Postworks is used successfully by several IPs.\u00a0 Widespread use of <strong>delivery by email<\/strong>, I think, is still a work in progress: Turnkey and others are geared up to assist, but I think the issues are in compiling a list of email addresses that can be used.\u00a0 Many IPs had moved to <strong>website delivery <\/strong>via a single R1.50 notice before the lockdown and I suspect that this process has become even more popular.<\/li>\n<li><strong>HMRC S100 documents<\/strong>: I have seen nothing to move forward from the Dear IP article (<a href=\"https:\/\/www.insolvencydirect.bis.gov.uk\/insolvencyprofessionandlegislation\/dearip\/dearipmill\/chapter8.htm#26\">https:\/\/www.insolvencydirect.bis.gov.uk\/insolvencyprofessionandlegislation\/dearip\/dearipmill\/chapter8.htm#26<\/a>) that stated that the HMRC email address is only to be used for \u201cthe initial pre-appointment notifications under the deemed consent or virtual meeting procedures\u201d, so it seems to me that Statements of Affairs and adjournment notices etc. must still be posted.<\/li>\n<li><strong>Court activities:<\/strong> as far as I can tell and as set out in the Temporary Insolvency Practice Direction, the courts are doing a phenomenal job in keeping their virtual doors open. Bravo!<\/li>\n<li><strong>Physical meetings<\/strong>: the RPBs published guidance that: \u201cwhere procedural meetings are required, virtual meetings will suffice in order to avoid breaching social distancing requirements.\u00a0 A reasonable approach will be required to handling any creditor requests for physical meetings\u201d (<a href=\"https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/joint-statement-by-icaew-and-the-ipa-regarding-measures-to-support-ips-during-the-covid-19-pandemic\">https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/joint-statement-by-icaew-and-the-ipa-regarding-measures-to-support-ips-during-the-covid-19-pandemic<\/a>). Personally, I\u2019m not sure how we\u2019re supposed to take this.\u00a0 Some may consider it <em>reasonable <\/em>to convene a physical meeting in a space large enough to accommodate social distancing.\u00a0 Some others could consider it reasonable to dismiss creditors\u2019 requests for a physical meeting altogether!\u00a0 In my view, the reasonable approach would be to contact the requesting creditors to explore whether their concerns can be addressed in another way, e.g. an informal discussion or, if there are formal decisions to be made, insist that the \u201cphysical\u201d meeting be held entirely remotely, thus requiring just a little departure from R15.6(6).<\/li>\n<li>It seems that the Government\u2019s intention to suspend the <strong>wrongful trading <\/strong>provisions has been met with some negativity by IPs (e.g. <a href=\"http:\/\/www.r3.org.uk\/press-policy-and-research\/news\/more\/29337\/covid-19-corporate-insolvency-framework-changes-r3-response\/\">r3.org.uk\/press-policy-and-research\/news\/more\/29337\/covid-19-corporate-insolvency-framework-changes-r3-response\/<\/a>), whereas the House of Commons\u2019 briefing paper quotes other bodies, including the IoD and ILA, as welcoming the news (<a href=\"https:\/\/commonslibrary.parliament.uk\/research-briefings\/cbp-8877\/\">https:\/\/commonslibrary.parliament.uk\/research-briefings\/cbp-8877\/<\/a>). Although the change has not yet been made, the Government plans that it will be retrospective from 1 March 2020 and it will continue for 3 months thereafter.<\/li>\n<\/ul>\n<p><strong><u>Statutory Filings \/ Deliveries<\/u><\/strong><\/p>\n<ul>\n<li>The RPBs\u2019 statement referred to above did not explain their expectations specifically in keeping up with <strong>progress reports<\/strong>, but it did acknowledge that the current difficulties could amount to a \u201creasonable excuse\u201d defence for breaching statutory requirements. The statement highlighted the need to \u201chave followed ethical principles and have justifiable, sound and well documented reasons for making those decisions\u201d, i.e. where \u201creasonable steps to comply\u201d are not enough to overcome the difficulties caused by the restrictions imposed on us in these extraordinary times.<\/li>\n<li>The news on Tuesday that <strong>Companies House <\/strong>is now accepting filings by email was extremely welcome (<a href=\"https:\/\/content.govdelivery.com\/accounts\/UKIS\/bulletins\/28550aa\">https:\/\/content.govdelivery.com\/accounts\/UKIS\/bulletins\/28550aa<\/a>). Understandably, it seems to be taking some time for Companies House to register documents at the moment and, if you physically mailed documents before they opened their doors to emails, you might consider sending them again by email.\u00a0 I\u2019m sure that Companies House won\u2019t thank me for that though, so only seriously time-critical documents, e.g. ADM-CVL conversions, might merit such a second attempt.\u00a0 The announcement included several warnings about how a failure to follow the instructions for emailing docs would result in them being rejected and, as Companies House filings by email are excluded from the deemed delivery provisions in R1.45, you would do well to ensure that staff follow the instructions to the letter.<\/li>\n<li>I\u2019m a little surprised that the InsS hasn\u2019t sought to extend the deadline for <strong>D-reports<\/strong>, especially as they have clearly considered the logistics of collecting <strong>books and records<\/strong>. At first glance, Dear IP 95 appeared to concede that IPs didn\u2019t need to take extreme measures to collect books and records, but when I looked closely, it did not such thing.\u00a0 It replaced the previous instruction that IPs should locate and ensure that books and records are secured and listed as appropriate with a requirement that IPs \u201cshould continue to take all possible steps to locate and secure\u201d them (<a href=\"https:\/\/content.govdelivery.com\/accounts\/UKIS\/bulletins\/284baba\">https:\/\/content.govdelivery.com\/accounts\/UKIS\/bulletins\/284baba<\/a>).\u00a0 \u201cAll possible steps\u201d?\u00a0 Well, we weren\u2019t going to be taking impossible ones!\u00a0 It\u2019s a shame that the InsS hasn\u2019t confirmed that IPs can limit steps to <em>reasonable <\/em>ones in these times.<\/li>\n<\/ul>\n<p><strong><u>\u00a0<\/u><\/strong><\/p>\n<p><strong><u>Case Administration<\/u><\/strong><\/p>\n<ul>\n<li>Although communications from the InsS, RPBs and HMRC regarding general case administration have been welcome, there has been little that has helped avoid cumbersome rules and other regulatory requirements. This is understandable, as the rules are the rules until a statutory instrument says otherwise.\u00a0 However, at least the announcements have given us some comfort that the bodies appreciate some of our difficulties.<\/li>\n<li>Included in these are, from the RPBs (<a href=\"https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/joint-statement-by-icaew-and-the-ipa-regarding-measures-to-support-ips-during-the-covid-19-pandemic\">https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/joint-statement-by-icaew-and-the-ipa-regarding-measures-to-support-ips-during-the-covid-19-pandemic<\/a>):\n<ul>\n<li>\u201cIPs may defer, on a short-term basis, <strong>non-priority work<\/strong> on existing cases (for instance investigatory work) and focus on new\/urgent areas. IPs must take all reasonable steps to progress case administration in the longer term and ensure stakeholder financial interests are not prejudiced.\u201d\u00a0 (Jo and I have been debating how, if on the other hand IPs have found that new engagements have taken a dip, now would be a good time to try to clear the decks for the future busy times.)<\/li>\n<li>It may be acceptable to allow markets to recover before <strong>selling assets<\/strong>.<\/li>\n<li>\u201cWhere a Notice of Intended Dividend has already been issued, we acknowledge that the <strong>payment of the dividend<\/strong> can be postponed and may be unable to be paid within two months\u201d\u2026 but you will need to remember that, in these circumstances, the NoID process will need to begin again later (R14.33(3)).<\/li>\n<li>\u201cIn order to provide flexibility for IPs to focus on new\/urgent matters and to allow time for market recovery, we are relaxing the expectation in existing <strong>MVLs<\/strong> that creditors will be paid in full within 12 months provided that the IP continues to consider the company will be solvent in the medium term when markets have recovered.\u201d<\/li>\n<li>\u201cWhen considering <strong>MVLs moving to a CVL<\/strong> (s.95), IPs may take longer than the deadline of seven days to notify creditors that the company is unable to pay debts in full within 12 months.\u201d<\/li>\n<li>\u201cWe acknowledge that it is not likely to be possible to comply with the <strong>SIP 3.1<\/strong> requirement to respond to debtor enquiries \u2018promptly\u2019 and to close IVAs \u2018promptly\u2019 and accept that IPs will need to prioritise their work through the crisis period.\u201d<\/li>\n<li>The RPBs have also acknowledged that IPs will exercise their discretion in relation to <strong>CVAs and IVAs<\/strong> and they \u201caccept that the <strong>discretion<\/strong> afforded to IPs in order to manage cases affected by the current crisis is necessarily wide\u201d. I\u2019m not sure how to take this: if a VA Proposal allows the Supervisor to exercise discretion, they hardly need the RPBs to tell them that they can do so, but if the Proposal does not allow any such discretion, then they cannot.\u00a0 There seems to be a veiled message here, much like a lot of the revised Ethics Code, which seems to have been written with the practices of volume\/consumer IVA providers in mind.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<ul>\n<li>HMRC\u2019s guidance (<a href=\"http:\/\/www.icaew.com\/-\/media\/corporate\/files\/technical\/insolvency\/insolvency-news\/coronavirus-insolvency-bulletin.ashx?la=en\">icaew.com\/-\/media\/corporate\/files\/technical\/insolvency\/insolvency-news\/coronavirus-insolvency-bulletin.ashx?la=en<\/a>) includes:\n<ul>\n<li>A similar peculiar statement that they would expect IPs to exercise any <strong>VA discretion<\/strong> \u201cto its maximum, with reference to creditors only if essential\u201d. Well yes, that\u2019s how a discretion should be exercised, isn\u2019t it?\u00a0 Let\u2019s hope that HMRC is now realising how unhelpful it is to IPs to have modified out many of the discretions that originally had been proposed!<\/li>\n<li>HMRC confirms that it will support a 3-month <strong>contribution break<\/strong> for coronavirus-impacted \u201ccustomers\u201d, but I think its in-bold confirmation that \u201cthere is no need to contact HMRC to request this deferment\u201d risks misleading some, not least debtors who may expect an automatic payment break. If a VA\u2019s terms do not allow the Supervisor to permit such a payment break, then this statement does not overcome this hurdle and creditors\u2019 approval must be sought.<\/li>\n<li>More helpfully, the guidance confirms that HMRC will not view <strong>post-VA VAT<\/strong> as due where the Government has already arranged for those VAT payments to be deferred. Unfortunately, the link HMRC has provided is already obsolete and the HMRC guidance does not refer also to the deferral of self-assessment income tax, but presumably the same principles apply?<\/li>\n<\/ul>\n<\/li>\n<li>The InsS continues to move into the electronic age, arranging for the following (to reduce the risks of fraudulent attempts, I\u2019m not providing links):\n<ul>\n<li>ISA payment requests to be submitted with an electronic signature;<\/li>\n<li>ISA payment requests and other CAU forms to be received by email; and<\/li>\n<li>IVA registration fees to be paid by BACS.<\/li>\n<\/ul>\n<\/li>\n<li>HMRC has done likewise with its opening the way for all dividends to be paid via BACS. Unfortunately, if you have any dividends to pay to HMRC by cheque, HMRC has asked that you \u201chold on to them\u201d (9 April release on <a href=\"http:\/\/www.insolvency-practitioners.org.uk\/press-publications\/recent-news\">insolvency-practitioners.org.uk\/press-publications\/recent-news<\/a>\u00a0UPDATE: additional guidance on paying dividends to HMRC by BACS is on this IPA page, dated 22\/04\/20).<\/li>\n<\/ul>\n<p><strong><u>And there\u2019s more<\/u><\/strong><\/p>\n<p>Finally, some miscellaneous notifications include:<\/p>\n<ul>\n<li>Must IPs complete <strong>file reviews<\/strong> in these times? Whilst not an official response, an RPB monitor emailed me swiftly after my last blog post.\u00a0 She observed that, of course, the objective of a file review is to ensure that the case progresses as it ought to and that a firm\u2019s reviewing policies should be designed to achieve this objective.\u00a0 Thus, if an IP decides to relax their firm\u2019s policy on file reviews in these extraordinary times, they should be considering how they can still try to achieve this objective and document why the firm\u2019s adjusted policy will not compromise effective and compliant case administration wherever possible in the circumstances.\u00a0 The monitor expressed the view that some kind of file review surely would still be possible in these times, even if access to the full case files is restricted.<\/li>\n<li>Can <strong>office holders furlough<\/strong> employees? The ICAEW blogged references from .gov.uk guidance (<a href=\"https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/the-coronavirus-job-retention-scheme---clarity-for-administrators-and-directors\">https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/the-coronavirus-job-retention-scheme&#8212;clarity-for-administrators-and-directors<\/a>), which describes the ability of Administrators to furlough staff as well as some of the finer points about directors\u2019 positions.\u00a0 Unfortunately, the .gov.uk guidance is not cut-and-dried and furloughing depends on the \u201creasonable likelihood of rehiring the workers\u201d, so understandably IPs are exercising a great deal of caution before treading a path that could lead to an expensive challenge down the line.<\/li>\n<li>Should <strong>IPs furlough<\/strong> their own staff? The ICAEW and the IPA have both issued warnings that they would not expect IPs to furlough to the extent that it compromises their ability to meet regulatory requirements (<a href=\"https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/business-continuity-for-insolvency-practitioners-during-covid-19\">https:\/\/ion.icaew.com\/insolvency\/b\/weblog\/posts\/business-continuity-for-insolvency-practitioners-during-covid-19<\/a>).\u00a0 The IPA has also required its members to keep it informed of the numbers and job titles of all furloughed staff as well as those unable to work through serious Covid-19 illness.<\/li>\n<li>Are IPs <strong>key workers<\/strong>? R3 blogged (<a href=\"http:\/\/www.r3.org.uk\/technical-library\/england-wales\/technical-guidance\/covid-19-contingency-arrangements\/more\/29316\/page\/1\/is-the-insolvency-profession-classed-as-a-key-sector-24-march-2020\/\">r3.org.uk\/technical-library\/england-wales\/technical-guidance\/covid-19-contingency-arrangements\/more\/29316\/page\/1\/is-the-insolvency-profession-classed-as-a-key-sector-24-march-2020\/<\/a>) that likely they are, especially when administering cases that involve managing businesses that themselves are in the key sectors.\u00a0 R3 also observed that the InsS considers that certain staff working in the RPS, Estate Accounts and ORs\u2019 offices are delivering \u201cessential public services\u201d.\u00a0 As much of an IP\u2019s work is necessary to enable such InsS staff to deliver these public services, it would seem to follow that the IPs\/staff would also be key workers.\u00a0 Shortly after this post, however, the IPA emailed its members reminding them that it is a decision for each employer per the guidance at <a href=\"http:\/\/www.gov.uk\/government\/publications\/coronavirus-covid-19-maintaining-educational-provision\/guidance-for-schools-colleges-and-local-authorities-on-maintaining-educational-provision\">www.gov.uk\/government\/publications\/coronavirus-covid-19-maintaining-educational-provision\/guidance-for-schools-colleges-and-local-authorities-on-maintaining-educational-provision<\/a>.<\/li>\n<li>Showing us southerners that it can be done, the Scottish Government brought into force the <strong>Coronavirus (Scotland) Act 2020<\/strong> in a matter of a couple of weeks. Amongst other things, it has extended the pre-insolvency moratorium period for individuals from 6 weeks to 6 months.\u00a0 More details can be found at <a href=\"https:\/\/www.aib.gov.uk\/news\/releases\/20202020\/0404\/coronavirus-scotland-act\">https:\/\/www.aib.gov.uk\/news\/releases\/20202020\/0404\/coronavirus-scotland-act<\/a><\/li>\n<\/ul>\n<p>Stay safe and keep well, everyone.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>In my last blog post, I published a wishlist of measures that would help IPs to do their jobs in these difficult times.\u00a0 Since then, some extraordinary steps have been taken very quickly to address many of them.\u00a0 Here, I &hellip; <a href=\"https:\/\/thecompliancealliance.co.uk\/blog\/news\/measures-to-help-ips\/\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","enabled":false},"version":2}},"categories":[54],"tags":[161,155,154,157,158,160,46,159,156,88],"class_list":["post-410","post","type-post","status-publish","format-standard","hentry","category-news","tag-companies-house","tag-coronavirus","tag-covid-19","tag-declaration-of-solvency","tag-furlough","tag-hmrc","tag-insolvency-service","tag-key-workers","tag-practice-direction","tag-rpbs"],"jetpack_publicize_connections":[],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"jetpack_shortlink":"https:\/\/wp.me\/p6i4jv-6C","_links":{"self":[{"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/posts\/410","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/comments?post=410"}],"version-history":[{"count":14,"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/posts\/410\/revisions"}],"predecessor-version":[{"id":1494,"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/posts\/410\/revisions\/1494"}],"wp:attachment":[{"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/media?parent=410"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/categories?post=410"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/thecompliancealliance.co.uk\/blog\/wp-json\/wp\/v2\/tags?post=410"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}