Who owns the loans? Inside the mystery of the loan charge recall scandal

The question nobody can answer

Luke* is a contractor for a Blue Light Service. His mental health is suffering because he wants to protect his wife and family from the stress caused by the loan charge recall letters.

“I realised I was being fobbed off,” recalls Luke, a self-employed contractor from the Midlands. “They kept telling me everything was in hand and that I didn’t need to engage with HMRC. The more questions I asked, the more suspicious I became.”

Luke left the contractor loan arrangement in 2015 after speaking directly to HMRC. More than a decade later, he says he is still receiving correspondence from companies claiming ownership of the same alleged debt. His files chart a remarkable succession of entities, each asserting rights over the loans and employing different approaches to recover them.

‘Who exactly am I supposed to owe this money to?’

Jodi* is a single mother from Scotland, whose child has additional needs. Her overarching question was: “Who exactly am I supposed to owe this money to?”

“When the letter from West 28th arrived in April 2026, I started asking questions,” she recalls. “I looked up Companies House and found Kenneth Arnold. Then I checked the FCA register because I couldn’t understand how an alleged Employee Benefit Trust loan had suddenly become a Consumer Credit Act loan.

“Citizens Advice told me to do nothing because, in their view, an EBT loan couldn’t simply be converted into a CCA loan without my agreement. The FCA gave similar advice. So I kept digging. I contacted Watchdog, Martin Lewis and later the Information Commissioner’s Office.

“The letter wasn’t threatening, but it wasn’t factual either. It talked about ‘monies owed by me’, ‘settling your credit agreement early’ and taking complaints to the Financial Ombudsman Service. My question was simple: what credit agreement? The only contact email on the letter was EBT@trethowans.com, yet they were describing it as a consumer credit agreement.

“Even the envelope raised questions. It came in an unbranded envelope with a Salisbury PO Box, and the registered office on the letter turned out to be the offices of the accountants who prepared West 28th’s accounts. The more I looked, the more questions I had.”

For more than a decade, the public debate around the loan charge focused almost exclusively on HMRC: its powers, its policies and its pursuit of unpaid tax. The official narrative is well documented. What has received far less scrutiny is what happened alongside it.

As promoters disappeared, schemes collapsed, and the law evolved, another market appears to have emerged — one in which the alleged rights to historic contractor loans were bought, sold and reassigned between private companies. HMRC’s guidance explains why tax may still be due in some circumstances, but it says little about how private firms came to assert ownership of the underlying loans. That raises an obvious question: when, and under what legal or commercial circumstances, did those historic loan books begin changing hands?

That is how Jodi describes the experience that has consumed much of the last decade. She entered an Employee Benefit Trust (EBT) arrangement in 2016 after being told by a recruitment provider to choose from a handful of payroll options. She says she was never warned that the loans might one day be recalled.

Today, while still dealing with an ongoing HMRC enquiry worth around £36,000, she finds herself fighting a second battle: correspondence from private companies claiming ownership of the same alleged loans. “When Felicitas first contacted me, my daughter was only six months old,” she says. “I despise them for taking away my joy at the time.”

When another letter arrived in April 2026 — this time from West 28th Street and its solicitors, Trethowans — her reaction was different. “I was angry that the rollercoaster was starting again.”

For Jodi, the question is no longer simply about tax. It is about ownership. Who now claims to own these historic loans, how did those rights change hands, and on what legal basis are they being enforced more than a decade after the original arrangements were entered into?

“The emotional impact is draining and needs to be put to bed.”

Not a story about debt collection letters

At first glance, this appears to be a story about debt collection. A contractor receives a letter demanding repayment of a historic loan. Solicitors become involved. Questions are asked. Files are exchanged.

But as we began examining the companies behind the correspondence, it became clear this investigation wasn’t really about the letters at all.

Instead, it became a journey through a corporate maze spanning the Isle of Man, Malta and the UK. Three names surfaced repeatedly. A succession of similarly named companies appeared and disappeared. Businesses traded under SIC codes that bore little obvious resemblance to the activities they appeared to be undertaking. Company accounts hinted at multi-million-pound transactions while other entities quietly entered liquidation or were struck off altogether. Shareholdings worth tens of millions of pounds appeared on paper. Loan books seemed to change hands, yet the documents explaining precisely how those rights travelled were often absent from the public record.

We examined more than 30 companies connected directly or indirectly to the trail. Twenty-one have since been dissolved or struck off, while others remain active at the centre of a web of assignments, acquisitions and unanswered questions.

Some proved to have only peripheral connections. Others formed part of the central corporate trail reconstructed below.

This investigation follows that paper trail. It starts with three men — Stephen Din, Kenneth Arnold and Adrian Sacco — and asks a deceptively simple question: how did the alleged rights to thousands of historic contractor loans travel through this network of companies, and who, ultimately, owns them today?

What the FCA told ContractorUK

Before publication, we asked the Financial Conduct Authority about the regulatory framework surrounding historic loan recovery.

The FCA declined to comment on any specific firm but explained that, in general, a third party seeking to recover money under a regulated consumer credit agreement would ordinarily be carrying on the regulated activity of debt collecting unless an exclusion applies.

It stressed, however, that whether an agreement falls within the Consumer Credit Act 1974 depends on “the terms of the agreement and surrounding facts”, not simply how it is described in later correspondence.

The regulator also advises consumers who are uncertain to obtain a copy of the original agreement and supporting documents from the creditor, and to check whether the firm is authorised using the FCA’s Firm Checker.

Finally, it reiterated that firms subject to its rules should ensure communications are fair, clear and not misleading, act in good faith and help consumers make informed decisions.

Who owns the alleged rights?

By this point in the investigation, three separate questions emerge.

1. Who owns the alleged loan rights today?
2. On what legal basis are those rights said to be enforceable — by assignment, contract, the Consumer Credit Act 1974, or some combination of those mechanisms?
3. Who ultimately benefits financially if contractors repay those historic loans?

The original schemes

Many contractors interviewed for this investigation entered into contractor remuneration schemes between approximately 2013 and 2016 through providers including Garraway, IQ Contracts, Infinity Solutions, Winchester Contractors, Darwin, DarwinPay, Longacre, Dynamic Partners and Sanzar Solutions, among others. Public commentary and correspondence reviewed during this investigation also identifies entities including BEC, DEC, Opus, Calligraphy and related businesses connected with parts of the wider contractor remuneration ecosystem.

Contractors typically entered into Master Credit Agreements and received a series of loan advances long before West 28th Street Limited existed.

Years later, many began receiving correspondence from Felicitas Solutions Limited, asserting that interest would accrue on those historic loans from April 2020 onwards.

What remains absent from the public record is the documentary bridge explaining precisely how those alleged rights travelled from the original contractor structures into Felicitas.

The Sacco connection

The Companies House record reveals a succession of companies using the Felicitas Solutions Limited name.

One was associated with Adrian Sacco, who appeared as a Person with Significant Control while the company itself was owned by Felicitas Group Limited. A separate Felicitas Solutions Limited was subsequently incorporated in 2022, initially under the control of Andrew Thompson before becoming jointly controlled by Thompson and Ann Sacco, who also became a director. That company existed for only a matter of months before being voluntarily dissolved. Public filings record those corporate events but do not explain their commercial purpose or whether either company formed part of the chain through which contractor loan rights were acquired.

The wider picture is also notable. Public records show Adrian Sacco associated with numerous businesses involved in payroll, employment and contractor services, including Best Employment Services (BEC), Dynamic Employment Contracts (DEC), Opus, Calligraphy and related companies operating within that wider commercial ecosystem. Several of those businesses have since entered liquidation, been dissolved or otherwise ceased trading. Adrian Sacco was subsequently disqualified as a UK company director, although records indicate continuing business interests outside the UK, including Malta.

None of those facts, individually, establish ownership of the contractor loan portfolio. Collectively, however, they demonstrate that the companies associated with the early contractor remuneration market formed a wider corporate network whose precise relationship to the later enforcement of the alleged loans remains unclear.

The emergence of West 28th

By 2026, contractors who had previously dealt with Felicitas found themselves corresponding instead with West 28th Street Limited.

The corrective annual statements issued by West 28th repeatedly refer to “our predecessor Felicitas Solutions Limited” and acknowledge that compliant Consumer Credit Act annual statements had not previously been issued before attempting to remedy that position.

The Companies House filings also reveal a significant corporate restructuring. West 28th Street is jointly owned through two corporate shareholders.

One half is held by Limelight Solutions Limited, a company associated through public filings with Kenneth Arnold. Although Limelight files abbreviated accounts showing no employees, it is not dormant. Its balance sheets disclose debtors, taxation liabilities, creditors and retained earnings, indicating continuing commercial activity despite the limited information available in the public record.

The remaining interest is held by West 13th Limited, wholly owned by Stephen Din.

At first glance, West 13th appears to possess extraordinary financial strength, reporting current assets of approximately £32 million and net assets exceeding £31 million, despite employing no staff.

However, the underlying Companies House filings tell a more nuanced story.

In May 2024, West 13th allotted 30 million new ordinary shares, leaving almost the entire subscription price unpaid. Confirmation statements subsequently identify Stephen Din as the holder of all 32 million issued ordinary shares. The public accounts do not disclose the composition of the company’s current assets, but the figures correspond remarkably closely with the unpaid share capital recorded in the share allotment filings. Whether those reported assets principally represent unpaid share capital receivable, rather than cash or operating assets, cannot be confirmed from the abbreviated accounts alone, but it is an obvious accounting question arising from the filings.

That distinction matters because it changes how West 13th’s apparent financial strength should be interpreted.

Following the money

West 28th’s own accounts also changed dramatically during the same period.

Earlier filings show a relatively modest financial services business. By 2025, however, the balance sheet reports approximately £2.7 million of stock, with further substantial balances recorded as loans and debtors. By 2026, the company continued to report approximately £2.6 million of stock, alongside more than £4 million of loans and liabilities.

The published accounts do not explain what comprises that stock, despite the company’s stated principal activity being financial intermediation. Nor do they explain whether those balances relate in any way to the historic contractor loan portfolio.

Separately, the accounts of West 28th Capital Limited record that the company ceased trading on 31 March 2025, after which its principal activity became that of a dormant company. Around the same period, West 28th Street’s own balance sheet expanded significantly. The filings record that sequence of events but do not explain the commercial rationale for the restructuring.

The missing bridge

This investigation deliberately stops short of one conclusion.

Despite reviewing Companies House filings, annual accounts, confirmation statements, share allotments, insolvency records and correspondence supplied by contractors, we have not located the assignment agreements or other legal instruments demonstrating the complete chain by which the alleged loan rights travelled:

• from the original contractor remuneration arrangements;
• into Felicitas Solutions Limited;
• and subsequently into West 28th Street Limited.

That missing documentation is not a minor technicality. It is the documentary bridge between the original loan arrangements and the present-day enforcement activity.

The publicly available evidence supports a reconstruction of the companies involved and the evolution of the corporate ownership structure. It does not, at present, establish the complete chain of legal title to the alleged loan rights.

Public records explain much about the companies involved. What they do not yet reveal is the complete legal chain by which the alleged rights to thousands of historic contractor loans travelled from the original remuneration arrangements to the companies now seeking repayment. Until that documentary bridge is available, the ownership of those loan books remains one of the least understood aspects of the loan charge story.

Right of reply

Prior to publication, ContractorUK sought comment from West 28th Street Limited, HM Revenue & Customs, Elysium Law, the Financial Conduct Authority and other parties referred to in this article. Any responses received after publication will be reported in a follow-up article.

*Names have been changed to protect the contractors’ identities.

If you are affected by the issues in this article, support is available from the Samaritans, free, 24 hours a day, on 116 123.