On 12 November 2014, the UK Supreme Court (in case citation number  UKSC 61) held that a 2012 UK Court of Appeal decision ( Lloyd's Rep IR 521) was incorrect and that the taking of an undisclosed commission did create an unfair relationship under the UK Consumer Credit Act 1974. The Supreme Court case concerned the sale of PPI in circumstances where a lender failed to disclose commission of 71.8% (payable to an intermediary, with which the plaintiff had previously settled a claim) on the PPI. The Court held that this created an unfair relationship as it involved a sufficiently extreme inequality of knowledge and understanding between the parties. The Court observed, however, that it can be difficult to determine the point at which a commission becomes so large that the relationship cannot be regarded as fair if the customer is unaware. Notably, the Supreme Court also held that the intermediary was the agent of the plaintiff rather than of the lender.