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REDD in the news: 12-18 December 2016

REDD-Monitor’s round-up of the week’s news on forests, climate change, and REDD. For regular updates, follow @reddmonitor on Twitter.

12 December 2016

How pursuit of carbon and fossil fuels harms the vulnerable
By Kristen Lyons, Cape Times, 12 December 2016
This year is set to be the hottest year on record.
Global temperatures are already 1.2°C above pre-industrial levels, and total reductions in emissions, committed by individual countries, far exceed globally agreed targets.
This puts us on track for dangerous climate change.
At a time when the transition to a low carbon future has never been more urgent, developed countries appear locked into ongoing support for the dirty fossil fuel industries.
In championing fossil fuels, indigenous peoples – First Nations and Aboriginal people – whose lives and territories have been affected by the destructive forces of colonisation, now face the violence of resource extractivism.
Indigenous peoples are defined as people with specific rights and law, bound by historical ties to a location.
Indigenous peoples from Canada, Australia, New Zealand, the Americas, northern Europe and the African continent, for example, face disproportionate discrimination, intimidation and violence compared to non-indigenous people. Their traditional lands are directly threatened by resource extractivism and its pollution. Developing countries and low lying island states are among the most defenceless in the context of a changing climate. African nations are among the most vulnerable.

Surge in methane threatens climate targets, scientists say
By Reed Alexander, CNN, 12 December 2016
While the world has been working to reduce carbon emissions to combat climate change, there’s been a troubling spike in another dangerous gas.
Methane levels in the atmosphere are rising faster than at any point in the past two decades, according to new research.
The findings are presented by the newly-released Global Methane Budget published Monday — part of an effort by 100 international scientists to understand just how much methane is rising, and why.

Global concentrations of methane are spiking
By Natasha Geiling, Think Progress, 12 December 2016
When it comes to climate change, carbon dioxide usually dominates the conversation — but it might be time to start paying particular attention to another greenhouse gas. Methane is 86 times more effective at trapping heat over a 20-year period than carbon dioxide, and scientists just announced it is increasing at an alarming rate.
According to new analysis published concurrently in the journals Environmental Research Letters and Earth System Science Data, methane concentrations are now growing at a higher rate than at any other time over the last two decades. And if these recent spikes in methane levels aren’t reined in, the papers’ authors warn that global temperatures could climb by as much as 4°C (7.2°F), blowing past the 2°C benchmark set by the Paris climate agreement.

REDD+, conservation and rural livelihoods
By Danna Ramsay, CIFOR Forests News, 12 December 2016
The ambitious global strategy to reduce emissions from deforestation and forest degradation known as REDD+ rocketed to the top of the climate agenda in 2007. And forests were explicitly recognized as a key part of the solution to climate change in the Paris Agreement. The recent COP22 in Marrakesh only reaffirmed this trend.
So what has happened between conception and implementation? And what does REDD+ now look like on the ground?
“Since 2007, hundreds of subnational REDD+ initiatives have been implemented across the tropics. They include small projects linked to the voluntary carbon market, as well as broad jurisdictional REDD+ approaches like Acre’s State System of Incentives for Environmental Services in Brazil,” said Amy Duchelle, a scientist at the Center for International Forestry Research (CIFOR) who leads the Center’s work on subnational REDD+ initiatives.

New issue of the REDD+ Resource now available!

UN-REDD Programme, 12 December 2016
The December/January 2017 edition of the UN-REDD Programme’s bi-monthly, multi-lingual news and information resource is now available, featuring updates from our partner countries, news and perspectives from REDD+ practicioners, publications, videos, jobs and more.

The Dark Side of the Forest
By Tim Christophersen, UNEP, 12 December 2016
When you shop at your local mall for furniture, or paper, have you ever considered whether these wood products come from legal sources? A recent report by the UN Environment and Interpol estimates that between 10 and 30 per cent of all roundwood traded globally is actually illegal. This means that illegal logging and related trade could be worth between 50 and 152 billion US$ per year. This money is lost to poor countries who urgently need tax revenues for their development.
Based on these alarming figures, the forest team at UN Environment took a closer look at the dimensions, impacts and responses to illegal logging. In collaboration with the International Union of Forestry Research Organizations, we assembled the best global experts in this field and developed a Rapid Response Assessment on Illegal Logging and Related Timber Trade. The report was launched on 3 December, during the Summit on Biological Diversity in Cancun/Mexico, and it reveals important information about the dark side of forestry.

Eq. Guinea kicks off development of investment plan
Central African Forest Initiative, 12 December 2016
In September 2016, the Presidency issued resolution number 3 creating the National Steering Committee in charge of the Elaboration of the National Investment Plan for the Protection and Conservation of the Forests of Equatorial Guinea. This Committee, composed of representatives of the central government, civil society, academia and the private sector, has the primary mandate to ensure success in the development of the National REDD+ Investment Plan (NIP).
ON 12-14 December, on the occasion of a mission by FAO, one of the CAFI implementing organizations, a workshop convening 50 stakeholders (the 25 members of the Steering Committee, and 25 other stakeholders from the Central Government, local governments, civil society and the private sector) will mark the launch of the development of the NIP.

[Spain] A Judge nullifies 12 equity release mortgages worth 6 million Euros
The Equity Release Victims Association, 12 December 2016
The sale was conducted through commission-driven financial advisors based in Estepona, Marbella and Fuengirola.
Court of First Instance 11 in Bilbao has ruled that twelve mortgage loans valued at 6 million Euros, granted to British families mostly in the Malaga province between 2004 and 2007, should be declared void.
The Court dealt with this case as all loans were granted at a Bilbao Notary Public and the representatives of the lender, SL Mortgage Funding nº1 Limited (SLMF), were also based in the Basque city, according to Lawbird Legal Services S.L.P.
These loans were sold to attain a reduction in potential inheritance tax, inasmuch as the mortgage would reduce the taxable value of the property, but also as a means to supplement the modest pensions received by the owners of the properties.

13 December 2016

What happens to international climate action when America’s top diplomat is an oil CEO?
By Natasha Geiling, Think Progress, 13 December 2016
As CEO of ExxonMobil, Rex Tillerson presided over the world’s largest publicly traded oil and gas company — a company that has come to represent, for climate activists, the very antithesis of climate action.
As Secretary of State, Tillerson will be the United States’ top diplomat, serving as an extension of U.S. policy worldwide. Past secretaries — especially John Kerry — have used the position to take an increasingly strong stance on climate action. It’s far from assured that Tillerson would do the same.
Unlike a handful of other top cabinet nominees — from EPA administrator to Secretary of the Interior — Tillerson does not appear to be a climate denier, telling an audience at the Oil & Money conference in October that “we [Exxon] share the view that the risks of climate change are real and require serious action.”

Success from the ground up?
By Kristen Evans and Mauel Guariguata, CIFOR Forests News, 13 December 2016
New global forest restoration initiatives – such as the Bonn Challenge, Initiative 20×20, AFR100, the Convention on Biological Diversity Aichi Targets – present an unparalleled opportunity to reverse the trend of deforestation and forest degradation in the coming years. However, those who work in forest restoration have countless stories of failed projects. How can we minimize these failures, learn from other restoration initiatives and build success from the ground up?
Restoration experts agree: monitoring is essential to restoration success. But is monitoring being given enough attention in the current major global initiatives?

Arctic’s year of crazy extremes as warming hits overdrive
By Seth Borenstein, AP, 13 December 2016
Warming at the top of the world has gone into overdrive, happening twice as fast as the rest of the globe, and extending unnatural heating into fall and winter, according to a new federal report.
In its annual Arctic Report Card , the National Oceanic and Atmospheric Administration on Tuesday tallied record after record of high temperatures, low sea ice, shrinking ice sheets and glaciers. Study lead author Jeremy Mathis, NOAA’s Arctic research chief, said it shows long-term Arctic warming trends deepening and becoming more obvious, with a disturbing creep into seasons beyond summer, when the Arctic usually rebuilds snow and ice.

EU ETS ‘could raise’ extra €120bn in climate funds
Argus, 13 December 2016
The EU could raise €120bn ($127bn) in additional climate finance through stronger measures to reduce free allocations in the emissions trading scheme (ETS) and raise prices, environmental group WWF said.
A European Commission proposal continues free ETS allocations up to 2030 and retains non-binding guidance that EU member states “should” spend more than half of their auction revenue on climate action. But the EU Parliament and Council can still amend the proposal before it becomes law.
A move towards full auctioning by 2026, an increase in the intake rate of the market stability reserve and a requirement that EU countries spend 100pc of their auction revenue on climate action would provide an extra €120bn in climate funding under the 2021-30 ETS phase four, WWF said.

[USA] Clean Energy Creates Jobs
By Danny Kennedy (California Clean Energy Fund), The Years Blog, 13 December 2016
If you want to create American jobs, it’s hard to beat renewable energy.
In the United States, there are already many more people working in solar energy than in the coal industry — and while coal is on the downward slope of its life cycle, solar and other renewables are just getting started.
Coal, which fuels about 30 percent of U.S. electric generation (and that share is shrinking), employs about 75,000 Americans throughout its value chain. So far, solar supplies just about 1 percent of electricity generation but is growing fast. Yet solar already employs 208,000 Americans, according to a job census commissioned by the Solar Foundation, and could well employ a million people within a decade.

14 December 2016

Has the Time Come to Count Emissions from Consumption?
By Arnold Tukker and Germana Canzi, IISD, 14 December 2016
The Paris Agreement, which came into force in early November 2016, requires the world to keep climate change below 2°C above pre-industrial levels, with an aim to stay below 1.5°C. The 1.5 target is particularly demanding and would require both major and rapid change in energy demand, as well as replacement of fossil fuels with low carbon alternatives.
Reducing energy demand will require changes in patterns of production and consumption. A number of policies addressing consumption – some voluntary and some regulatory – are already in place at European Union level, such as policies to phase out the most inefficient energy using appliances and improve the energy performance of buildings. However, there are broader issues at play that need to be addressed.

Reflecting on Years of Living Dangerously
By Sarah Spengeman, The Years Blog, 14 December 2016
My husband and I have been tuning in regularly to watch Season Two of Years of Living Dangerously on the National Geographic Channel, and so much of what we have seen this season has hit close to home. Last week, Don Cheadle traveled to the Central Valley of California — where I grew up — to see firsthand how the drought has devastated family farms there in the Valley and is posing a threat to food supplies worldwide. This week, we saw our former governor, Arnold Schwarzenegger, fly to the Middle East to learn how our military is facing the threats posed by climate change. Governor Schwarzenegger’s conversations with members of our military overseas reminded me of how I felt when my younger brother was in Iraq — I have never prayed so hard in my life. In this episode we see men and women in our armed services driving hundreds of miles across the desert to deliver fuel to our military bases. As one driver described the situation, the convoys are easy targets, and thousands of our military personnel have already died along the way.

Beyond tree planting
By Kate Evans, CIFOR Forests News, 14 December 2016
When most people think of forest restoration, they think of planting trees.
But at the scales needed to meet ambitious global land restoration targets, the costs involved are prohibitive – from buying millions of seedlings to paying people to plant and maintain them. But there is a powerful, cost-effective alternative: nature itself.
In a new paper, Manuel Guariguata from the Center for International Forestry Research (CIFOR) and Robin Chazdon from the University of Connecticut argue that harnessing forests’ natural ability to repair and regrow is essential if countries hope to meet achieve restoration goals like the Bonn Challenge and the 20×20 Initiative.

Brazil set for ‘environmental civil war’, warns minister
By Megan Darby, Climate Home, 14 December 2016
Brazil’s government is divided on a bill to tear up federal environmental regulations and hand responsibility to states.
Promoted by the rural lobby, the proposal would exempt farming and forestry – responsible for nearly 70% of the country’s greenhouse gas emissions – from current licensing laws.
Eliseu Padilha, chief of staff to president Michel Temer, is understood to support the bill, which was presented to the parliamentary finance committee on Wednesday.
But environment minister Jose Sarney Filho warned in a letter to the presidency it would spark “environmental civil war” (guerra ambiental entre os estados), with states competing to offer the weakest restrictions on development.

EU to cancel 1bn pollution permits in market reforms
By Megan Darby, Climate Home, 14 December 2016
The EU will cancel a billion pollution permits under a package of carbon market reforms agreed by EU lawmakers on Thursday.
The industry-friendly European People’s Party Group reached a compromise with advocates for more ambitious climate policy in left-wing, green and liberal blocs.
The environmental committee also recommended shrinking the cap on greenhouse gas emissions for the bloc’s heavy industry faster next decade – although that could be overturned by member states.
Haege Fjellheim, analyst at Thompson Reuters Point Carbon, said the package “sends a bullish signal” on carbon prices compared to previous versions.

Guatemalan land defenders are under threat and need justice
By Andrew Fandino, Friends of the Earth US, 14 December 2016
Guatemalan land rights activist Rigoberto Lima Choc was shot and killed outside a courthouse in Peten, Guatemala on September 18, 2015. The murder occurred one day after a ruling by Judge Karla Hernandez, in a new USAID-supported environmental court, to suspend the palm oil operations of REPSA, a local company, due to its alleged massive contamination of the Pasion River. Rigoberto had been one of the first people to document and denounce the contamination, which has been referred to by activists and experts alike as “ecocide,” with over a million fish dead and over 12,000 people affected in 17 different communities. The court’s ruling of ecocide was precedent-setting — or would have been, if the violence that followed had not undermined the court’s authority.

[Indonesia] Organic Fertilizer Used to Combat Forest Fires in Riau
By Ratri M. Siniwi, Jakarta Globe, 14 December 2016
As forest fires continue to plague Riau, farmers in Rokan Hilir district took it upon themselves to find a more efficient way to combat the problem by using homemade organic fertilizer.
With the help of Riau University, farmers have been using ferns, locally known as pakis – which are considered a weed in palm oil plantations – as their main source for the fertilizer.
The ferns are mixed with brown sugar, coconut water, leftover rice water and chicken manure and covered for three weeks to allow the active ingredients to act.
“Usually the ferns are burnt [by the farmers] during the dry season, but by making use of it [as fertilizer], reduces the possibility of fires,” Riau University researcher Besri Nasrul said. “Farmers would need to check for moisture levels weekly for the compost to be processed.”

[Pakistan] 4th meeting on REDD+ held
Pakistan Observer, 14 December 2016
The 4th meeting of the National Steering Committee on REDD+ was convened under the chairmanship of Federal Secretary, Ministry of Climate Change today.
The meeting was attended by provincial secretary of GB and representatives of other respective provincial forest departments, representatives of forest owners from KPK, GB and Punjab nominated by respective provincial forest departments, NGOs, UNDP, IUCN, Civil Society Groups and relevant ministries of federal government.

[USA] U.N. environment chief concerned at climate science sceptics among Trump picks
By Kanupriya Kapoor, Reuters, 14 December 2016
Some elite U.S. politicians’ denial of the science backing up climate change is worrying, the United Nations environment chief said on Wednesday, adding that the fight against global warming would continue, even without the United States.
U.S. President-elect Donald Trump has in the past dismissed climate change as a “hoax”, vowing during his campaign to pull the United States out of the Paris Climate Agreement, a deal among nearly 200 countries to curb global warming.
Trump, who won the November election on a range of populist promises to deregulate and revive the energy sector, has appointed to his cabinet climate change sceptics, including oil magnates – moves that have angered green groups.

15 December 2016

Regional Court dismisses climate lawsuit against RWE – Claimant likely to appeal
Germanwatch, 15 December 2016
Today, the Regional Court Essen dismissed the “climate lawsuit” of Peruvian mountain guide and farmer Saúl Luciano Lliuya against RWE. The civil court justified its decision inter alia by pointing to a lack of “legal causality,” which it argued does not exist despite the fact that there may be a “scientific causality”. The claimant and his lawyer had hoped to proceed to the evidentiary stage with the aim of clarifying the legal liabilities of large contributors to climate change for providing protection from the risks associated with climate impacts. “We nevertheless believe the lawsuit is well-founded and that a legal causality does exist,” affirms attorney at law Dr. Roda Verheyen (Hamburg). “We will now most likely appeal the case to prove RWE’s partial responsibility at the Higher Regional Court Hamm. My client and I will make the final decision after reviewing the written verdict.”

2016: A unique opportunity to get it right on forests and climate change
By Ellysar Baroudy, World Bank, 15 December 2016
If ever there was a year to make significant progress on forest conservation and climate change, it was 2016. Coming on the heels of the historic COP21 Paris Agreement, 2016 was a year to demonstrate the commitment the World Bank Group has to support countries as they take forward their nationally determined contributions to address our global climate change challenge. It’s gratifying to look back on 2016 and feel that we contributed to harnessing this momentum and sense of urgency; especially in showing how sustainable land use, including sustainable forest management, is critical to achieving the ambitious targets set out in the Paris Agreement.

[Brazil] Our forest is shedding tears
Greenpeace, 15 December 2016
On November 27, the Munduruku Indigenous People traveled from their home in the Amazon to Brazil’s capital to demand the official recognition of the Sawré Muybu Indigenous Land on the Tapajós River. The Brazilian government is planning a series of dams that would flood portions of the Amazon rainforest and threaten their way of life. Maria Leusa Munduruku spoke with Vânia Alves from Greenpeace Brazil about the journey from her home to Brasília to demand protection of their traditional lands.

EU lawmakers back more ambition in carbon market reform
By Alissa de Carbonnel, Reuters, 15 December 2016
EU lawmakers on Thursday endorsed draft reforms of the carbon market post-2020 that aim to balance greater cuts in greenhouse gases with protection for energy-intensive industries.
The European Union’s market for carbon credits, essentially tradeable permits allowing industry to pollute, has suffered from excess supply since the economic crisis, depressing prices and heightening the need for reform.
The draft, backed by the European Parliament’s Environment Committee, calls for a faster removal of surplus carbon permits from the EU’s emission trading system from 2021.

[India] Vardha douses fears of forest fires in national parks
By R. Krishna Kumar, The Hindu, 15 December 2016
Cyclone Vardha’s effect brought moderate but widespread showers across Bandipur and Nagarahole national parks at a time when authorities were bracing up for an outbreak of forest fires. Large swathes of both the national parks had turned bone dry well ahead of summer owing to the failure of the south-west monsoon this year.
There were even a few minor fires reported in Bandipur. So, the recent rainfall has been a relief for the authorities as well as the wildlife.
Bandipur National Park director Hiralal told The Hindu that though the rainfall had covered the entire 874.78 sq km of national park and this would provide relief for at least two to three weeks. ‘Fresh shoots of vegetation coupled with moisture due to rain will help stave off forest fires for two to three weeks,” he said.

16 December 2016

Assessing deforestation risk
Proforest, 16 December 2016
In its third annual Forest 500 report released this month, the Global Canopy Programme assessed the commitments made by influential actors to address deforestation in palm oil, soy, cattle and timber product supply chains.
Of the 166 palm oil companies assessed, more than 60% have sustainability policies and over 55% have forest policies. Companies are making new commitments to eliminate deforestation across a range of commodity supply chains. Between 2014 and 2016, the number of companies committed to addressing deforestation in all relevant commodity supply chains increased by 5%.
All these companies need tools and processes to help them identify where deforestation occurs in their supply chains. And this is where geospatial risk assessments can help.

FLEGT and REDD+ synergies and impacts in the Congo Basin: lessons for global forest governance
European Forest Institute, 16 December 2016
In the past four decades, a range of policies and governance mechanisms have been created to deal with complex problems associated with the use of the world’s forests. Two of the most recent international policies are the European Union s Action Plan on Forest Law Enforcement, Governance and Trade (FLEGT) and its bilaterally negotiated Voluntary Partnership Agreements (VPAs), and the United Nations mitigation policy on Reducing Emissions from Deforestation and Forest Degradation (REDD+). The emergence of these policies with some overlaps brings into question the success of these policies: do they build effective and enduring forest governance in isolation or in coordination?

[Ghana] National Plantation Dev. Programme yields result
Business Ghana, 16 December 2016
Ghana has planted about 190,449.92 hectares of trees under the national plantation development programme, as at December 1, 2016.
Dr. Gloria Djaney Djagbletey, Head of Forest and Climate Change Division of the Forestry Research Institute of Ghana (FORIG) of the Council for Scientific and Industrial Research (CSIR-FORIG), who disclosed this, said that the only specie being planted was Teak.
At the opening of a three-day annual review and planning session of FORIG, the theme, “Making research findings relevant to end users,” Dr. Djagbletey suggested the planting of Cedrela and other tree species.
The National Forest Plantation Development Programme was launched in September 2001, to accelerate the rate of establishment of forest plantations.

WWF and Greenpeace break with Indonesia’s pulp and paper giant
By Jeremy Hace, The Guardian, 16 December 2016
The construction of a 3km canal in Indonesia has led Greenpeace and WWF to suspend its partnership with one of Indonesia’s biggest pulp and paper companies.
Riau Andalan Pulp and Paper (Rapp), a subsidiary of Asia Pacific Resources International Limited (April), dug the canal through thick peat forest on the island of Pedang, just off the east coast of Sumatra.
In doing so, April not only flouted its own sustainability standards but went against government regulations and a letter of instruction issued by the Ministry of Environment and Forestry last year asking companies to block existing canals.

[Indonesia] Minister Siti: Land and Forest Fire Reduced in 2016
TEMPO, 16 December 2016
Environment and Forestry Minister Siti Nurbaya Bakar revealed that the forest and land fire throughout 2016 have successfully been reduced. This can be seen by the number of hot spots that has dropped compared to the previous year.
Based on NOAA satellite observation, the number of hot spots has been reduced by 82 percent. Meanwhile, the Terra-Aqua satellite shows that it is down by 90 percent. “The 2016 evaluation is great,” she said on Friday, December 16, 2016.
The index of air pollution standards (ISPU) in 2016 only reached moderate levels.
The Minister stated that based on the end of October 2016’s data, there were 190,000 hectares on fire. “Last year was more than two million,” she said.

[USA] Solar capacity has increased 99% since last quarter
By Natasha Geiling, Think Progress, 16 December 2016
The U.S. solar industry just experienced a quarter of record-breaking growth, with 4,143 megawatts (or million watts) of solar capacity added between July and September. That’s a 99 percent increase over the previous quarter, and a 191 percent increase over the same time period last year.
Those numbers come from a quarterly report issued by the Solar Energy Industries Association (SEIA) and market analysis firm GTM Research. According to the report, an average of one new megawatt of solar generating capacity came online every 32 minutes between July and September. From the beginning of the year through September, new solar capacity represented 39 percent of all new electric generating capacity in the United States — second only to natural gas in terms of the share of new electric capacity.

17 December 2016

Indonesia’s strategy: No fires = no haze
By Arlina Arshad, The Straits Times, 17 December 2016
Instead of fighting fires, the Indonesian government said it hoped to channel more efforts upstream to prevent them, as it announced a three-year national programme to combat haze and rehabilitate destroyed peatland.
The efforts will start at the village level, to create more “fire-free villages” or “Desa Bebas Api” in Bahasa Indonesia. The central and local authorities will work with the private sector to get local communities more involved in preventing fires.
For instance, small-scale farmers who still clear their land using slash-and-burn methods will be taught land-clearing techniques such as composting or burning land waste in covered drums instead.
While such programmes are already available,they are run by plantation firms and are small-scale, involving only a few villages.

[Indonesia] Govt sets ambitious target of reducing forest fires by half
By Hans Nicholas Jong, The Jakarta Post, 17 December 2016
The government has unveiled a grand strategy to reduce annual land and forest fires in the country over the next three years, aiming to halve the number of hot spots by 2019.
The grand strategy is an ambitious nationwide effort that will involve no fewer than 16 ministries and government agencies, encompassing 731 fire-prone villages in 66 cities and regencies in eight provinces: Riau, Jamb… [R-M: Subscription needed]

[Indonesia] Palm oil bill fails to address key problems
By Steani Ribka, The Jakarta Post, 17 December 2016
Several stakeholders have criticized the palm oil bill currently being deliberated, saying that the bill does not tackle the sector’s major issues, including land legality and sustainable cultivation.
Vice chairwoman of the Office of the Coordinating Economic Minister’s Indonesian Sustainable Palm Oil (ISPO) empowerment team, Diah Suradireja, said the bill still lacked solutions to land… [R-M: Subscription needed]

18 December 2016

Marbella boiler room mis sold €6 million of loans to British buyers
By Rob Hogan, The Olive Press, 18 December 2016
A boiler room in Marbella mis sold loans worth €6 million to unwitting expats.
A judge in Bilbao has nullified 12 equity release mortgages sold by financial advisers in Estepona, Marbella and Fuengirola.
Sold to reduce the potential inheritance tax on a property, SL Mortgage Funding Limited (SLMF) did not have any of the necessary permits to sell such loans.
In fact, SLMF did not have any regulatory approval to legally raise funds from the public when it was selling equity release mortgages between 2004 and 2007.
A spokesman for Marbella-based lawfirm Lawbird said that the ruling ‘proves’ that the company was operating as a boiler room.

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