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Copyright © International Chamber of Commerce (ICC). All rights reserved. ( Source of the document: ICC Digital Library )
Article
UCP 600 sub-articles 14 (d) and 30 (b)
When the credit did not stipulate the exact type of weight to be used for invoicing purposes, was an invoice using the "commercial weight" acceptable as long as the tolerance of plus or minus five percent had been respected?
Query [TA 786rev2]
We kindly request your official opinion for the following query related to a documentary credit issued subject to UCP 600.
Description of goods is stated under the documentary credit as:
VISCOSE STAPLE FIBER 1.2 D X 32 MM BRIGHT
QUANTITY: 500,000 KGS UNIT PRICE: 1.84 USD/KG
VISCOSE STAPLE FIBER 1.2 D X 38 MM BRIGHT
TOTAL FOB (INCOTERMS 2010) CITY X COUNTRY C USD 1,840,000 (-/+ 5 %)
Partial shipments were allowed.
VISCOSE STAPLE FIBER 1.2 D X 32 MM BRIGHT was shipped, and related documents for USD 945,443.52 were presented to the issuing bank. On the certificate of origin, bill of lading and weight list, the gross and net weights were shown as 504,402 KGS and 501,604.80 KGS respectively. On the other hand, commercial weight was also shown as 513,828 KGS on the weight list and commercial invoice. The amount of the commercial invoice was based on this commercial weight, and there was no other quantity stated on the document.
Since there is no condition in the documentary credit that invoicing is to be on a commercial weight basis, is the commercial invoice acceptable in terms of the quantity and calculation of amount?
Analysis
UCP 600 sub-article 14 (d) states: "Data in a document, when read in context with the credit, the document itself and international standard banking practice, need not be identical to, but must not conflict with, data in that document, any other stipulated document or the credit."
The quantity of goods to be supplied is stated in kilograms without any additional specification in the credit. The commercial invoice and the weight list both indicated a "commercial weight", whilst the weight list, bill of lading and certificate of origin also showed a gross and net weight which differed from the commercial weight.
The credit stated that the amount was subject to a tolerance of plus or minus five per cent. Although there is no indication that the same tolerance was applicable to the quantity of the goods, UCP 600 sub-article 30 (b) permits a variation of plus or minus 5 per cent provided the total amount of the drawings does not exceed the amount of the credit.
In respect of the difference between the gross, net and commercial weights, there is no conflict in as much as the weight list indicates the same commercial weight that is the basis upon which the drawing amount has been established. There is no requirement for the invoice to show the gross or net weights.
As the credit did not stipulate the exact type of weight to be used for invoicing purposes, an invoice using the "commercial weight" is acceptable as long as the tolerance of plus or minus five per cent has been respected, which is the case for this drawing.
When a drawing amount is to be based upon the weight of the goods that are shipped, multiplied by a unit price, it is the responsibility of the issuing bank to ensure that the credit indicates the basis under which that amount is to be determined, i.e., the net, gross, commercial weight or other formula absent which any basis used to determine the drawing amount is acceptable.
There is no conflict between the net and gross weights that appear on the documents.
This opinion relates solely to the facts of this query. A note with additional information on the fiber industry is detailed below.
For Information Only: "Commercial weight" is a term commonly used in the determination of weight for fibers, a process that also takes into consideration the impact of moisture regain on the weight of the fiber. The incorporation of moisture regain accounts for why a commercial weight will be greater than a net weight, i.e., the moisture being taken into consideration after establishment of the dry weight. In the fiber industry, commercial weight is an understood term. Whilst it would have been preferable for this to be stated in the credit, it does not detract from the fact that "commercial weight" is an acceptable term for the described goods. For other commodities, other practices exist.
For Information Only:
Conclusion
Based on the Analysis above, the commercial invoice is acceptable in terms of the quantity invoiced and the calculation of the invoice amount.
UCP 600 sub-article 14 (a)
Are the front and reverse of a bill of lading considered to be the same document, regardless of whether a page number is displayed on one side, both sides or neither side?
Query [TA 787]
We kindly ask for your official opinion on the following issue associated with the interpretation of a page no. indicated on the bill of lading.
A Country I Bank issued a credit available by negotiation where the MT700 in field 47A item no. 3 stated the following: "+ B/L presented in incomplete number of page(s) is not acceptable."
A presentation of documents, including a full set of charter party bills of lading, was considered to be compliant by the negotiating bank, which sent the documents to the issuing bank on 12 March 2013. The negotiating bank paid the beneficiary and was waiting for reimbursement from the issuing bank.
The issuing bank refused the documents for the following reason: "Bill of lading presented in incomplete number of pages."
The issuing bank insisted the discrepancy was valid on the following grounds: The full set charter party bill of lading presented has indicated "Page 01" on the reverse side of the B/L, but the front page did not indicate "Page 02" to declare it was the 2nd page of the B/L.
The negotiating bank contested the refusal notice of the issuing bank on the following grounds:
1. According to UCP 600, banks are not required to examine the terms and conditions of carriage that apply to the various transport documents and, as a result, the page of the document that contains such terms and conditions or a reference to a source where such terms and conditions may be reviewed. Under a charter party bill of lading, banks would have no cause to review the reverse of the document other than for any endorsements. Banks are only required to examine the data that appears on the face of the charter party bill of lading, and this indicates shipment of 157,358WMT of Iron Concentrate - Sinter Feed Namisa - SDNM, which is the same cargo mentioned in the beneficiary's invoice and provides evidence that the shipment has been made in full.
2. The front page of the B/L did not indicate wording such as "continuation to page 2" or "continue to next page" or "page 1 of 2" that could lead to an interpretation there would be a 2nd page or supplement/appendix attached to it.
3. There is no such requirement in the credit that the front page of the document is to state the page no., and marking page 01 on the back page has no meaning at all, so why should the front page need to declare itself as page 02?
4. The back page has properly indicated an endorsement by the shipper for transfer of title of the goods. According to UCP 600, banks should check whether the B/L is properly endorsed; the checking of terms and conditions of carriage is not required.
5. The subject page numbering does not affect the title of the goods and is not a material discrepancy that affected the shipment and goods quality, so the issuing bank should not identify this discrepancy as a reason to refuse the documents and help the L/C applicant delay payment, nor to allow it to have the chance for a possible reduction of the invoice value due to a drop in commodity prices.
Despite a strongly-worded payment tracer sent by the negotiating bank on 25 March 2013, no response was received. As the beneficiary wanted to receive payment as early as possible and to avoid a material discrepancy - late presentation - the issuing bank chose to return the documents to the negotiating bank. It arranged for an appointed agent in Country H to amend the front page of the charter party bill of lading, and the issuing bank has finally made payment to the negotiating bank two weeks after negotiation of the compliant presentation.
We will be grateful to have the opinion of the ICC Banking Commission in respect of the discrepancy mentioned above.
UCP 600 sub-article 14 (a) states that "a nominated bank acting on its nomination, a confirming bank, if any, and the issuing bank must examine a presentation to determine, on the basis of the documents alone, whether or not the documents appear on their face to constitute a complying presentation."
The requirement in the credit for "B/L presented in incomplete number of pages is not acceptable" is unclear as to its exact intention. There is no indication in the bill of lading that there are additional pages.
The front and reverse of a bill of lading are considered to be the same document, regardless of whether a page number is displayed on one side, both sides or neither side. In practice, many bills of lading are issued with only one side numbered.
The bill of lading is acceptable.
UCP 600 article 27; sub-article 14 (a)
Whether a presented bill of lading was clean when there were no defects but when the vessel had been placed under arrest in the port of loading
Query [TA 788rev]
We would like to request the ICC Banking Commission's advisors to prepare an ICC opinion on an issue that we received from one of our member banks as follows:
"A letter of credit issued by the issuing bank covered the shipment of 120,000 mt +/- 10% of coal from Country S to Country I. Partial shipments were allowed and presentation of documents later than 21 days was acceptable. Among the documents required was a full set of charter party bills of lading. Since the delivery basis was FOB, it was the buyer's duty to charter the vessel.
The seller started loading the goods onto the vessel. When almost 24,000 mt were on board, an arrest order for the vessel was issued in the port of loading. According to information available, the arrest was neither directed against the seller nor against the buyer, and it did not affect the cargo loaded. For information purposes: the cargo could not be unloaded, since the port of loading was specifically equipped to load coal but not to unload it.
About a month later, the seller was able to present documents under the letter of credit. Among these documents was a full set of charter party bills of lading, issued on April 12 but showing 'clean on board 18 February 2013'. The bill of lading also showed the remark 'vessel under arrest 18 February 2013'.
The documents were sent to the issuing bank, which refused them on the following grounds: 'Bill of Lading is not clean. It bears the clause as follows: Vessel under arrest 18 February 2013.'
The issuing bank also listed two other discrepancies, which were later withdrawn. The bank also informed us that the documents would be returned.
We rejected the discrepancy. Article 27 of the UCP clearly defines a 'clean transport document' as a document not bearing any clause declaring a defective condition of the goods or their packaging, which is definitely not the case here. Furthermore, the Incoterm FOB means that the seller has to deliver the goods on board the vessel nominated by the buyer at the named port of shipment. This condition has been clearly fulfilled here.
The issuing bank insisted that the discrepancy was valid: 'We confirm our stand on refusal of the documents since the presented bill of lading is claused and clearly indicates the defect with the remark 'vessel under arrest 18th February 2013 becomes a claused bill of lading.'
We will appreciate receiving your official opinion on the following questions:
1. Does the remark 'vessel under arrest 18 February 2013' render the B/L unclean?
2. If your answer to question 1 is 'no', is the issuing bank obliged to accept the B/L as credit conform?"
We would be grateful if the advisors could prepare the draft official opinion and circulate it so that it could be discussed at the next meeting of the Commission.
UCP 600 article 27 states: "A bank will only accept a clean transport document. A clean transport document is one bearing no clause or notation expressly declaring a defective condition of the goods or their packaging. The word 'clean' need not appear on a transport document, even if a credit has a requirement for that transport document to be 'clean on board.'"
UCP 600 sub-article 14 (a) states: "A nominated bank acting on its nomination, a confirming bank, if any, and the issuing bank must examine a presentation to determine, on the basis of the documents alone, whether or not the documents appear on their face to constitute a complying presentation."
On the basis of the transport document, there is no indication that the goods or their packaging were defective. Accordingly, the transport document was compliant and the presentation must be honoured.
Arrest of a vessel and any subsequent obligation or liability arising out of such arrest is a matter of law and outside the remit of UCP 600.
1. The remark on the arrest of the vessel does not render the charter party bill of lading unclean.
2. Yes, the issuing bank must accept the presented bill of lading.
UCP sub-articles 14 (c) and 14 (i)
Where the documentary credit included a "presentation period rule" different from the one expressed in UCP 600 sub-article 14 (c), was UCP 600 article 14 (c) effectively modified, i.e., do modifications to the rules necessarily require a bank to specifically state the article that has been modified or the manner in which it has been modified?
Query [TA 789rev]
We seek the opinion of the ICC Banking Commission on a dispute between a credit issuing bank and the negotiating bank on the "Presentation Period" and UCP 600 sub-article 14 (c)
UCP 600 sub-article 14 (c) states: "A presentation including one or more original transport documents subject to articles 19, 20, 21, 22, 23, 24 or 25 must be made by or on behalf of the beneficiary not later than 21 calendar days after the date of shipment as described in these rules, but in any event not later than the expiry date of the credit."
What is in dispute is whether UCP 600 sub-article 14 (c) is to be applied in a credit that does call for a B/L, but which stipulates a presentation condition that makes a reference, not to the date of shipment but to another document or a non-shipment event. Specifically, in this case, the credit requires an on-board B/L but its presentation condition reads: "Documents must be presented not later than 10 calendar days after credit issuance date."
Documents were tendered in good time (i.e., within 10 days of the credit issuance date), but the B/L showed an on-board date of six months earlier. The issuing bank listed discrepancy: "Presented later than 21 days after the date of shipment". The negotiating bank disputed the discrepancy.
The issuing bank's contention is that while presentation must indeed occur within 10 calendar days of the credit issuance date, the B/L that the credit calls for must still not be more than 21 days old at the time of its presentation, in accordance with UCP 600 sub-article 14 (c). That is, a stipulated presentation period that is not tied to the shipment date does not automatically or implicitly waive UCP 600 sub-article 14 (c). In other words, unless otherwise expressed, a B/L presented under a credit must not be more than 21 days old, notwithstanding that the credit's presentation period does not reference the shipment date at all.
Given the availability of UCP 600 sub-article 14 (i), the presentation of very old documents is not impossible. If the issuing bank's intention is indeed to accept and finance such old documents, the credit should either explicitly exclude UCP 600 sub-article 14 (c) or provide for a larger B/L-related presentation period. Otherwise, a presentation such as the one above is discrepant.
The negotiating bank's contention is that the credit is concerned with the speed of presentation and not at all with the age of the B/L and other documents. Given that shipment may have preceded credit issuance, and with the availability of UCP 600 sub-article 14 (i), keeping the shipment date as the reference point would only complicate matters. The negotiating bank's argument is that, by its non-reference to the shipment date, the credit implicitly excludes UCP 600 sub-article 14 (c). In other words, if the presentation period does not mention a shipment date, then UCP 600 sub-article 14 (c) is not to be applied even if the presentation includes a called-for B/L Then, it does not matter whether the B/L is 22 days old, 22 weeks old, 22 months old or whatever, so long as it is presented within whatever stipulated presentation period.
In this case, the presentation was indeed within 10 calendar days of the credit issuance date, and thus is compliant, notwithstanding that the B/L shows an on-board date of six months ago. Meanwhile, if the age of the B/L/documents is of concern, the credit should either exclude UCP 600 sub-article 14 (i) or disallow documents dated earlier than a certain date.
In summary:
Credit calls for on-board B/L
Presentation period is ". . . not later than 10 calendar days after credit issuance date"
Credit does not mention anything relating to UCP 600 sub-articles 14 (c) or 14 (i)
A. Documents presented within 10 calendar days of credit issuance date
B. B/L shows on-board date of six months earlier
1. Issuing bank treats as discrepant (in view of UCP 600 sub-article 14 (c))
2. Negotiating bank disagrees (in view of non-reference to shipment date in the presentation period condition)
We respectfully request the opinion of the ICC Banking Commission.
The credit required presentation of an on board B/L, and also states: "Documents must be presented not later than 10 calendar days after credit issuance date."
UCP 600 sub-article 14 (i) states: "A document may be dated prior to the issuance date of the credit, but must not be dated later than its date of presentation."
This has previously been addressed in ICC Opinion R716/TA704rev, which is quoted below as follows:
" ... UCP 600 Article 1 includes the following sentence: '[T]hey [UCP 600 rules] are binding on all parties thereto unless expressly modified or excluded by the credit.'
The condition stated in the credit should be seen as an emphasis of the wording in article 1 and not one that detracts from, or implies a different approach from, the position envisaged by the article. In effect, the wording in the credit was not necessary to emphasize that the terms and conditions of the credit may modify or exclude one or more rules in the UCP.
The issue concerns the word 'expressly' and whether or not this requires a bank to specifically indicate in the credit where a modification of the rules is being made and the extent to which it is being made. Ultimately, it is the examination of documents against the terms and conditions of the credit that will determine whether or not a presentation is complying. The rules contained in UCP 600 will apply to that credit to the extent that the credit does not contain one or more terms and conditions that modify one or more of those rules.
Modifications to the rules do not necessarily require a bank to specifically state the article that has been modified or the manner in which it has been modified. For example, the insertion of '15' in field 48 (Presentation Period) of an MT700 would modify the rule stated in sub-article 14 (c) that presentation must be made by or on behalf of the beneficiary not later than 21 calendar days after the date of shipment. There is no explanation of the modification, but the insertion of '15' clearly creates a modified rule in respect of the presentation period.
It should be noted that when a rule is to be excluded for whatever reason, there must be an express indication of this, by saying, for example, 'Sub-article 14 (i) is excluded.' In most cases when an exclusion occurs, the credit will need to contain a new rule replacing the language or article excluded. In respect of the exclusion of sub-article 14 (i), this would necessitate the credit stating the new conditions relating to the dating of documents.
The wording in the credit is not recommended for use. The wording in article 1 is sufficient to explain that the terms and conditions of a credit may modify or exclude a rule. A modification of a rule may be made by the simple insertion of data that creates a situation different from that envisaged by the UCP. It should be recognized that there may be circumstances in which an issuing bank is required to modify a rule due to the circumstances of a transaction, and this may require the issuing bank to provide more detailed wording to avoid the risk of ambiguity in the credit. In this respect, reference should be made to ISBP Publication No. 681 paragraph 2, which states: '[T] he applicant bears the risk of any ambiguity in its instructions to issue or amend a credit.'"
The documentary credit includes a "presentation period rule" different from the one expressed in UCP 600 sub-article 14 (c).
Consequently, UCP 600 sub-article 14 (c) has effectively been modified, and the wording in the credit applies. The documents comply.
UCP 600 sub-articles 14 (f), 14 (c) and 14 (d) and article 20; ISBP 681 paragraph 115 and ISBP 745 paragraph A19
A standby stated two specific requirements for the photocopy of original bill of lading, neither of which was a requirement to examine the photocopy under UCP 600 article 20. By inclusion of those specific requirements, did the issuing bank preclude itself from refusing the document based on any discrepancy other than the two mentioned?
Query [TA 790rev]
We would like to seek an official opinion of the ICC Banking Commission on the following question relating to documents presented under a standby letter of credit issued subject to UCP 600.
The SBLC was issued by Bank A, available by sight payment with the issuing bank and contained the following additional conditions inter alia:
47A: Additional Conditions:
+ In case of the documents show a shipment by vessel, a photocopy of original bill of lading must be presented with the other documents.
The photocopy of bill of lading will be accepted by us as presented except if not complying with the next two conditions:
1. in case of sea transport, the transport document must indicate IMO ship number of carrying vessel.
2. shipment by a shipping co and/or by ship under sanctions US/EU/UN are forbidden. The beneficiary presented to the advising bank a photocopy of a charter party bill of lading together with the other required documents.
The issuing bank refused to honour, stating the following discrepancy: "Presentation of B/L used with charter party, not foreseen in the SBLC terms (as per paragraph 115 of ISBP)" [Pub 681].
The advising bank sent the following message to issuing bank: "We draw your attention on the terms of your SBLC: 47A: additional conditions: the photocopy of bill of lading will be accepted by us as presented except ... (and especially on paragraph 20 of ISBP: 20) copies of transport documents are not transport documents for the purpose of UCP 600 articles 19-25 and sub-article 14 (c) UCP 600.
The transport articles apply where there are original transport documents presented. Where a credit allows for the presentation of a copy transport document rather than an original, the credit must explicitly state the details to be shown. Where copies (non-negotiable) are presented, they need not evidence signature, dates, etc. Therefore, paragraph 115 of ISBP (Pub 681) is not applicable. We would like for you to check this matter again and confirm the payment and also value applied."
The issuing bank maintained its refusal and did not honour the documents.
We would be grateful if you would kindly provide us with your opinion as to whether the issuing bank has the right refuse payment under the standby letter of credit on the basis of the discrepancy raised.
According to the Additional Conditions of the Standby Letter of Credit, presentation of a photocopy of an original bill of lading was required when any document presented under the standby letter of credit indicated that the means of transport was a ship. The standby letter of credit stipulated two requirements for the photocopy (the fulfillment of which is not under dispute), but at the same time stated that the photocopy of the bill of lading will be accepted as presented.
UCP 600 articles 19-25 on transport documents apply only when a credit requires presentation of at least one original transport document. A requirement for presentation of a photocopy of a transport document would fall under UCP 600 sub-article 14 (f), which states: "If a credit requires presentation of a document other than a transport document, insurance document or commercial invoice, without stipulating by whom the document is to be issued or its data content, banks will accept the document as presented if its content appears to fulfil the function of the required document and otherwise complies with sub-article 14 (d)."
For a presentation of a photocopy of an original transport document, UCP 600 sub-article 14 (f) applies (see also ISBP 745 paragraph A6 (a)), which determines the standard of examination of such photocopies. A photocopy of a transport document has no apparent function under a SBLC other than demonstrating that transport has taken place.
The term "accepted by us as presented" does not by itself have a definite meaning under UCP 600 concerning the extent of the disclaimer intended by the issuing bank. Without defining the meaning of this term, issuing banks should not include it in the wording of any credit. ISBP 745 Paragraph A19) offers - in the absence of such a definition - the following clarification: "a presentation may consist of one or more of the stipulated documents provided they are presented within the expiry date of the credit and the drawing amount is within that which is available under the credit. The documents will not otherwise be examined for compliance under the credit or UCP 600, including whether they are presented in the required number of originals or copies."
The SBLC stated two specific requirements for the photocopy of original bill of lading, neither of which was a requirement to examine the photocopy under UCP 600 article 20.
By inclusion of those specific requirements, the issuing bank has precluded itself from refusing the document based on any other discrepancy than the two mentioned.
The discrepancy cited by the issuing bank is not valid under the terms of the standby letter of credit, and the issuing bank would be required to honour the presentation.
UCP 600 sub-article 20 (a) (i); ISBP 745 paragraphs E5 (c)
When a bill of lading was signed by a carrier in preprinted text and by a shipping company as agent with its stamp and signature, was this a discrepancy?
Query [TA 791rev]
We kindly ask your official opinion on the following query related to documents presented under a documentary credit issued subject to UCP 600.
Our question relates to the practical application UCP 600 sub-article 20 (a) (i).
The documentary credit in question called (amongst other documents) for a bill of lading. After presenting the documents to the issuing bank, a refusal message was issued citing the following discrepancy: "THE SIGNATURE OF AGENT ON B/L NOT INDICATING ON WHOSE BEHALF IT IS SIGNING"
Facts:
The bill of lading was signed in the following manner:
Signing field:
Quote: 'M Lines, Ltd. as Carrier' [this is a preprinted text]
By Company A Shipping Ltd As Agents"
Further the document included the stamp and signature of "Company A Shipping Ltd".
We ask you kindly to advise if the discrepancy cited by the issuing bank is correct.
UCP 600 sub-article 20 (a) (i) states:"a. A bill of lading, however named, must appear to:
i. indicate the name of the carrier and be signed by:
- the carrier or a named agent for or on behalf of the carrier, or
- the master or a named agent for or on behalf of the master.
- Any signature by the carrier, master or agent must be identified as that of the carrier, master or agent.
Any signature by an agent must indicate whether the agent has signed for or on behalf of the carrier or for or on behalf of the master."
The bill of lading signature block is:
"M Lines Ltd as Carrier" [this is a preprinted text]
ISBP 745 paragraph E5 (C) states that "When an agent signs a bill of lading for [or on behalf of] the carrier, the agent is to be named and, in addition, to indicate that it is signing as 'agent for (name), the carrier' or as 'agent on behalf of (name), the carrier' or words of similar effect." In this particular example, the word "By" means "For and on behalf of the above".
On the basis of the information provided regarding the bill of lading, there is no discrepancy. Accordingly, the bill of lading was compliant and the presentation must be honoured.
UCP 600 sub-articles 17 (b) and 28 (a); article 17; ISBP 745 paragraphs A27, A28 and K5
Is the insurance document an original and does it bear an apparently original signature? Is it signed by an insurance company and countersigned by a named entity?
Query [TA 792rev]
We kindly ask an official opinion on the following issue associated with the treatment of original documents under UCP 600. It is confirmed that the below query is based on an actual case experienced by our ICC national committee member bank on whose behalf this question is submitted.
We attach two insurance documents with identification details redacted. The documents were presented in exclusively "black on white" form without apparently any additions being made after they were printed.
Can the Banking Commission confirm that these two documents would be acceptable under UCP 600 as clarified by ISBP 745, assuming all other terms and conditions of the relevant credit are complied with?
UCP 600 sub-article 17 (b) states: "A bank shall treat as an original any document bearing an apparently original signature, mark, stamp, or label of the issuer of the document, unless the document itself indicates that it is not an original."
ISBP 745 paragraph A27 states: "A document bearing an apparently original signature, mark, stamp or label of the issuer will be considered to be an original unless it states it is a copy. Banks do not determine whether such a signature, mark, stamp or label of the issuer has been applied in a manual or facsimile form and, as such, any document bearing such method of authentication will satisfy the requirements of UCP 600 article 17."
Both the insurance documents appear to bear apparently original signatures.
ISBP 745 paragraph A28 states: "Documents issued in more than one original may be marked 'Original', 'Duplicate', 'Triplicate'. None of these markings will disqualify a document as an original." Both the insurance documents are marked "Original".
UCP 600 sub-article 28 (a) states: "An insurance document, such as an insurance policy, an insurance certificate or a declaration under an open cover, must appear to be issued and signed by an insurance company, an underwriter or their agents or proxies."
The insurance document issued by Company K is signed as a proxy of the underwriters and the signature for the Council of Company l confirms that authority.
The insurance document issued by Company A is signed by an insurance company.
ISBP 745 paragraph K5 states:
"When an insurance document requires a countersignature by the issuer, the assured or a named entity, it must be countersigned."
The insurance document issued by Company A has been countersigned by a named entity.
Both the insurance documents are compliant with the signing requirements to evidence an original document.
Both the insurance documents appear to be originals as stated in UCP 600 and ISBP 745.