06 May 2016

Mortgagee Sale: Glover No.2 v. BNZ

Attempts by BNZ to force a sale of four multi-million dollar properties in the Auckland seaside suburb of St Heliers subject to a protracted legal battle between estranged husband and wife were blocked by the Court of Appeal.  BNZ failed to issue correctly worded default notices.
Gregory Olliver and Sarah Sparks separated in July 2012.  Prior to that they were jointly involved in a proposed property development spanning nine residential sites in St Heliers covering some 10,000 square metres. A family trust set up by Ms Sparks has a 60% interest in the joint venture; Mr Olliver’s family trust 40%. 
The court was told Bank of New Zealand lent $6.75 million in 2009 to purchase five of the properties: the Tranche One properties.  BNZ took security over “all present and after-acquired property” of CIT Holdings, the joint venture vehicle used.  CIT later took ownership of four further properties: the Tranche Two properties.  Tranche Two was intended to survive the joint venture, mortgage free, as a residence.  The proposed joint venture was not successful.  The two former spouses were at each other’s throats.  The debt due to the BNZ was escalating, reaching $10.1 million and rising by 2014.
The CIT loan became a major headache for BNZ.  It took a series of court hearings to prise the Tranche One properties out of Ms Sparks control.  Interests associated with Mr Olliver made offers to buy all nine properties at a price which Ms Sparks alleges undervalues them.  In a flurry of legal activity Ms Sparks had caveats lodged against all the Tranche One and Tranche Two properties to protect her interest in the joint venture and she filed a relationship property claim.  BNZ filed its own caveat against the Tranche Two properties; these properties were acquired after the 2009 loan. 
The court was told all parties had agreed to a sale of Tranche One properties.  Ms Sparks dug in her heels over selling Tranche Two.  She alleges BNZ and her former husband might collude to gain control of the Tranche Two properties at her expense.  In particular, she complains much of the BNZ debt might be booked against Tranche Two sales when BNZ did not lend against the Tranche Two properties.
The Court of Appeal said BNZ’s security over CIT’s “after-acquired” property gave the Bank an equitable interest over the Tranche Two properties.  BNZ’s Property Law Act default notice warning of a forced sale of the Tranche Two properties made reference to security taken under the Personal Property Securities Act.  This Act applies to security taken over goods, not equitable mortgages over land.  BNZ needs to issue an amended Property Law Act notice to force a sale of Tranche Two land, the Court ruled.           
Glover No.2 Ltd v. BNZ – Court of Appeal (6.05.16)

16.076