On 21 February 2009 the Banking Act (the “Act”) became effective as law. Also on 21 February, the statutory instruments dealing with safeguards for partial property transfers (the “Safeguards Order”) and “no creditor worse off ” provisions (the “NCWO Order,” together with the Safeguards Order, the “Orders”) came into effect.1 Together, these replace the temporary special resolution regime set up in the wake of the Northern Rock rescue.