An email labeled “Notice of Levy” from a debt collector is usually not, by itself, a legally effective levy in the Philippines. It may be a valid demand for payment, a warning that the creditor intends to sue, or an electronic copy of genuine court documents. But an actual levy ordinarily requires lawful court process and implementation by a sheriff or another officer authorized by law.

The most important question is not simply, “Was the notice sent by email?” The questions are: Was a real case filed? Is there a valid judgment or court order? Did the court issue a writ? Did an authorized sheriff perform the acts required to levy the particular property?

This discussion covers ordinary private debts such as loans, credit cards, financing accounts, unpaid services, and similar civil obligations. Different rules may apply to tax levies by the BIR or local government, forfeiture proceedings, and other enforcement powers created by special laws.

The Direct Answer: When Is an Email Notice of Levy Valid?

An email notice may fall into one of three situations:

1. It is only a collection demand

A debt collector may email you demanding payment and warning that legal action may follow. The email may be legally relevant as a demand letter, but it does not give the collector the power to seize your bank account, salary, vehicle, land, or household property.

A private collection agency does not become a sheriff merely because it uses legal language, attaches a document called a “Notice of Levy,” or has a lawyer sign the email.

2. It contains a copy of genuine court or sheriff documents

A collection agency or creditor’s lawyer may send you an electronic copy of a real writ of execution, notice of garnishment, sheriff’s notice of levy, or notice of sale.

In that situation, the email itself did not create the levy. However, it may be informing you about a levy that has already been implemented through official court procedures. You should verify the documents immediately rather than dismissing them merely because they arrived by email.

3. It is an official electronic court communication

Electronic service is now widely recognized in Philippine civil procedure. Under the Supreme Court’s Rule 13-A on electronic filing and service, subsequent pleadings, court orders, judgments, and other papers in covered civil cases may be served through the email addresses of record. Summons, however, remains governed principally by Rule 14 and its specific service requirements. (Supreme Court E-Library)

An official email from a court, clerk of court, or sheriff therefore should not be ignored. But its authenticity and the underlying case must still be verified independently.

What Does “Levy” Mean Under Philippine Law?

A levy is the legal act by which property of a judgment debtor is placed under execution so it can be used to satisfy a court judgment.

The person who won the case is called the judgment creditor. The person ordered to pay is the judgment debtor.

A related procedure is garnishment, which is used when money or property belonging to the debtor is held by another person or institution. Common examples include:

Bank deposits held by a bank
Money owed to the debtor by a customer
Shares of stock held or recorded by a corporation
Certain compensation or receivables held by an employer or business

Under Rule 39 of the Rules of Court, execution of a money judgment is implemented by the sheriff or proper officer. The officer first demands immediate payment. If the debtor cannot pay, the officer may levy property sufficient to satisfy the judgment and lawful fees. (Supreme Court E-Library)

Document or communication	Who normally issues it	What it legally does
Demand letter	Creditor, lawyer, or collection agency	Requests payment; does not seize property
Complaint and summons	Court process initiated by the creditor	Informs the defendant that a case has been filed
Judgment or final order	Court	Determines the parties’ rights and obligations
Writ of execution	Court	Commands the sheriff or proper officer to enforce the judgment
Notice of levy	Sheriff or authorized officer	Records or communicates that property has been placed under execution
Notice of garnishment	Sheriff or authorized officer	Directs a bank or third party holding the debtor’s assets to retain them subject to court process
Notice of sheriff’s sale	Sheriff	Announces the public auction of levied property

What Is Required for a Legally Effective Levy?

For an ordinary private debt, the following elements are generally necessary.

1. There must be a valid judgment or enforceable court order

A creditor normally must sue, establish the debt, and obtain a judgment that has become final and executory before execution may issue.

There are exceptions. For example, a court may issue a writ of preliminary attachment under Rule 57 before final judgment when specific legal grounds are established and the applicant posts the required bond. But even then, attachment must come from the court and be implemented by an authorized officer—not created unilaterally by a collection agency.

A final judgment may generally be enforced by motion within five years from its entry. After that period, enforcement usually requires an independent action to revive the judgment, subject to the applicable rules on prescription. (Supreme Court E-Library)

2. The court must issue a proper writ

A writ of execution must be issued in the name of the Republic of the Philippines and must identify the court, case number, case title, dispositive portion of the judgment, and amount to be collected. It must be directed to the sheriff or another proper officer. (Supreme Court E-Library)

The Supreme Court has repeatedly ruled that a writ must conform to the judgment it enforces. It cannot add interest, penalties, parties, property, or obligations that the judgment did not authorize. In Philippine American Accident Insurance Co. v. Flores, the Court invalidated an execution that went beyond the judgment’s terms. (Lawphil)

3. The sheriff or proper officer must implement the writ

A creditor, lawyer, or debt collector cannot personally exercise the sheriff’s coercive authority.

For a money judgment, the sheriff generally:

Demands immediate payment from the debtor.
Receives payment only through the procedures allowed by the Rules.
If payment is not made, levies property sufficient to cover the judgment and lawful fees.
Observes the debtor’s right to indicate which property should be levied.
Levies personal property before real property when the debtor does not make a choice and sufficient personal property is available.

The sheriff should not seize substantially more property than reasonably necessary. In Hulst v. PR Builders, Inc., the Supreme Court explained that the sheriff must avoid an unreasonable and unnecessary levy and sell only enough property to satisfy the judgment and lawful fees. (Supreme Court E-Library)

4. The required act must be performed for the type of property involved

A levy is not accomplished merely by sending words in an email. The Rules require specific acts.

Movable property capable of manual delivery: The sheriff ordinarily takes the property into custody.
Bank deposits, debts, and credits: The sheriff serves a notice of garnishment on the bank or other person holding the debtor’s money.
Shares of stock: Notice is served on the corporation or entity maintaining the ownership records.
Registered land: The required order, description, and notice must be filed with the Registry of Deeds, and copies must be left with the occupant or person in possession as required by the Rules.
Other real property: The sheriff must follow the applicable registration, posting, and service procedures.

For real property, the Supreme Court has described filing the execution documents with the Register of Deeds and leaving the required copies with the occupant as essential acts for an effective levy. (Supreme Court E-Library)

Does the Electronic Commerce Act Make an Email Levy Valid?

Republic Act No. 8792, or the Electronic Commerce Act of 2000, provides that electronic data messages and electronic documents cannot be denied legal effect merely because they are electronic. An email can therefore be legally recognized as a communication, demand, notice, contract-related document, or evidence when authenticity and reliability are established. (Lawphil)

But RA 8792 does not eliminate substantive legal requirements.

An email cannot:

Create a court judgment that does not exist
Convert a collector into a sheriff
Replace a court-issued writ
Cure lack of jurisdiction over the debtor
Substitute for registration of a real-property levy
Substitute for service of garnishment on a bank
Authorize seizure of exempt property
Expand the amount or obligations stated in the judgment

In practical terms, electronic form may be valid, but the sender must still have legal authority and the required procedure must still have been followed.

How to Check Whether the Email and Levy Are Genuine

1. Preserve everything

Save:

The original email
Complete email headers
All attachments
Screenshots of the message
The sender’s address
Payment instructions
Telephone numbers and account details
Dates and times of calls or messages

Do not rely solely on screenshots sent by the collector. Keep the original electronic files because their metadata may help establish where they came from.

2. Do not use the contact details in the suspicious email to verify it

A fraudulent notice may include a fake court telephone number or a number answered by another member of the same collection operation.

Find the court independently through the Supreme Court’s official Court Locator. Contact the Office of the Clerk of Court or the identified branch using the information listed by the Judiciary. Rule 13-A also directs parties to official court email directories rather than unverified addresses. (Supreme Court E-Library)

Ask the court to confirm:

Whether the case number exists
Whether you are a named party
The complete case title
The date and nature of the judgment
Whether the judgment is final
Whether a writ of execution was issued
The name of the assigned sheriff
Whether a notice of levy or garnishment was issued
Whether a sheriff’s sale has been scheduled

3. Examine the alleged court papers

A genuine writ or notice should contain details capable of independent verification, such as:

Name and branch of the court
Judicial region
Case number
Complete case title
Names of the parties
Date of judgment or order
Date the writ was issued
Amount ordered by the court
Name and signature of the issuing court officer
Name of the sheriff implementing the writ
Description of the property or garnished funds

A court seal, signature image, or official-looking letterhead is not conclusive. Electronic documents can be copied or altered.

4. Request the underlying records

Depending on your situation, obtain or inspect copies of:

The complaint
The summons and proof or return of service
Your answer, if any
The decision or judgment
The order declaring the judgment final, when applicable
The entry of judgment
The motion for execution
The writ of execution
The sheriff’s return
The notice of levy, garnishment, or sale

Certification and copying charges vary by court and by the number of pages. Payments for official court documents should be made through the court’s authorized collection process and supported by official receipts.

5. Check the affected property independently

For a bank account

Contact the bank’s branch, legal department, or compliance unit through official channels. Ask whether the account restriction is based on a notice of garnishment and request the following information, subject to the bank’s disclosure procedures:

Court and branch
Case number
Name of the sheriff
Date the notice was received
Amount covered
Name of the judgment creditor

A real garnishment is effected through service on the bank. The bank may therefore restrict funds before the debtor personally reads an email from the creditor or collector. Under Rule 39, the garnishee must report whether it holds sufficient credits, and the Rules provide further periods for delivery when ordered. (Supreme Court E-Library)

For registered land

Obtain a current certified true copy of the title from the Registry of Deeds or through authorized Land Registration Authority channels. Check whether a notice of levy has been annotated and compare its case number, date, creditor, debtor, and court with the email.

For a vehicle or movable property

Ask for the sheriff’s identification, writ, inventory, acknowledgment receipt, and the exact court that issued the process. Do not surrender property to a private collector who cannot establish official authority.

6. Verify the debt and the collector’s authority

Even where the debt may be genuine, ask for:

Name of the original creditor
Loan or account agreement
Complete statement of account
Breakdown of principal, interest, penalties, attorney’s fees, and collection charges
Proof that the collection agency was authorized
Proof of assignment if the debt was sold
Record of your payments and credits

Do not pay merely because the collector knows your name, address, account number, or employer. Such information may have come from an old account, a data breach, an unauthorized disclosure, or identity theft.

7. Be careful about written admissions

Article 1155 of the Civil Code provides that prescription may be interrupted by filing an action in court, a written extrajudicial demand by the creditor, or a written acknowledgment of the debt by the debtor. An unnecessary email saying “I admit I owe this amount” can therefore have consequences, especially in disputes involving an old account. (Lawphil)

A verification response may instead state that:

You are requesting documents and validation.
You do not admit the amount or legal enforceability of the claim.
You reserve all defenses.
All further communications should identify the creditor, account, court case, and legal basis.

Warning Signs That the Notice May Be Fake or Misleading

Treat the email with particular caution when it:

Gives no court name, branch, or case number
Refers vaguely to a “National Court,” “Legal Department,” or “Enforcement Division”
Claims a private collector has personally issued a writ
Threatens immediate arrest solely for nonpayment
Demands payment within a few hours to “cancel the levy”
Requires payment to a personal bank account, e-wallet, cryptocurrency wallet, or gift-card account
Asks for an OTP, PIN, online banking password, or remote access to your device
Uses an email address unrelated to the court, creditor, or law office
Contains amounts that do not match your records
Threatens to seize property belonging to relatives who are not debtors or guarantors
Refuses to provide the judgment, writ, and sheriff’s details
Claims that no court case is necessary
Threatens to publish your debt to your employer, neighbors, social-media contacts, or family

A collector’s use of words such as “final demand,” “legal department,” “pre-levy,” or “warrant processing” does not establish that judicial proceedings exist.

What to Do If the Levy Is Genuine

A verified levy requires prompt action because execution and auction procedures move according to court deadlines.

Review whether the writ and levy match the judgment

Possible grounds for questioning execution may include:

There is no final and executory judgment.
The writ was issued against the wrong person.
The court never acquired jurisdiction over you.
The judgment has already been paid, settled, reversed, or modified.
The amount in the writ exceeds the judgment.
The writ adds unauthorized interest, penalties, or attorney’s fees.
The property belongs to someone else.
The property is legally exempt from execution.
The levy is excessive.
Required levy, registration, notice, or sale procedures were not followed.
The judgment can no longer be enforced by motion because the applicable period has expired.

The court that issued the writ generally retains control over its execution and may resolve motions involving the validity of the writ, exemptions, redemption, and errors by the sheriff. (Supreme Court E-Library)

Pay only through verified and documented channels

Rule 39 permits payment to the judgment creditor or authorized representative in the presence of the sheriff, or through other procedures specified by the Rules. A sheriff should not demand that a check be made payable personally to the sheriff. Payments must be properly receipted and reported. (Supreme Court E-Library)

Before paying, confirm:

The exact balance under the judgment
Credits for all prior payments
Lawful interest and fees
Who is authorized to receive payment
How satisfaction of judgment will be recorded
Whether the levy, garnishment, or sale will be lifted in writing

Identify exempt property

Rule 39 protects several categories of property from execution, subject to exceptions. These include certain necessary household items, tools and implements used for livelihood, professional equipment, legal support, specified pensions and benefits, and wages necessary for the debtor’s family during the four months preceding the levy. (Supreme Court E-Library)

The family home may also be exempt under Articles 153 and 155 of the Family Code. However, the protection is not absolute. Exceptions include tax debts, debts incurred before the family home was constituted, debts secured by a mortgage over the property, and obligations owed to persons who supplied labor, professional services, or materials for its construction. (Lawphil)

Calling a property a “family home” is not always enough. Occupancy, ownership, timing of the debt, the nature of the obligation, and supporting documents may all matter.

Act immediately if you never knew about the case

A debtor who first learns of a judgment through a levy should inspect the court record and the proof of service.

Depending on the facts and timing, possible remedies may involve a motion before the issuing court, a petition for relief from judgment, an appeal-related remedy, annulment of judgment, or a challenge based on lack of jurisdiction.

A petition for relief under Rule 38 is exceptionally time-sensitive. It must generally be filed within 60 days after learning of the judgment, order, or proceeding and no more than six months after its entry or occurrence. Both periods must be satisfied. In Madarang v. Spouses Morales, the Supreme Court emphasized that these periods are strict and jurisdictional. (Supreme Court E-Library)

Use a third-party claim when the property belongs to someone else

If the sheriff levies property owned by a person who is not the judgment debtor, the owner may use a third-party claim, commonly called a terceria.

Under Rule 39, the third-party claimant serves an affidavit of ownership or right to possession on the sheriff and gives a copy to the judgment creditor. An independent action to recover the property or protect ownership may also be available. The Supreme Court has explained that these remedies are cumulative and that filing a terceria is not always a prerequisite to a separate action. (Supreme Court E-Library)

Useful proof may include:

Certificate of title
Deed of sale
Official receipts
Vehicle registration
Delivery records
Bank records
Tax declarations
Inventory and accounting records
Proof of payment
Affidavits explaining possession and ownership

Important Levy and Sheriff’s Sale Timelines

The exact timeline depends on the type of property, court orders, objections, postponements, and service issues. The following periods commonly appear under Rule 39:

Procedure	General period or requirement
Enforcement of final judgment by motion	Within five years from entry of judgment
Garnishee’s report on credits or funds held	Within five days from service of garnishment
Delivery of garnished amount after the required notice	Within ten working days from service of the notice requiring delivery
Notice of sale of ordinary personal property	Posting for at least five days
Notice of sale of real property	Posting for twenty days
Newspaper publication for certain real-property sales	Once a week for two consecutive weeks when the assessed value exceeds ₱50,000
Written notice to the judgment debtor before sale	At least three days before the sale
Redemption of real property sold on execution	Generally within one year from registration of the certificate of sale

These periods appear in the Rules of Court provisions on execution, levy, sale, and redemption. (Supreme Court E-Library)

Payment of the judgment and lawful costs before the sale may prevent the auction. Filing an objection alone, however, does not always suspend a scheduled sale. A sheriff ordinarily continues implementing the writ unless the court issues an order stopping, recalling, or modifying the execution. (Supreme Court E-Library)

What If the Email Is Fake, Deceptive, or Harassing?

A creditor has the right to make lawful collection efforts. That right does not include impersonating a court, inventing a levy, threatening action that cannot legally be taken, or publicly humiliating the borrower.

Rules for lending and financing companies

SEC Memorandum Circular No. 18, Series of 2019 regulates unfair debt-collection practices by financing companies, lending companies, and their third-party collection service providers.

Prohibited conduct includes:

Threats of violence or criminal means
Threats to take action that cannot legally be taken
Obscene language, insults, or profane language
False representations or deceptive collection methods
Unauthorized publication or disclosure of borrower information
Unreasonable collection communications, generally including contact before 6:00 a.m. or after 10:00 p.m., subject to specified exceptions
Contacting persons in the borrower’s contact list who are not guarantors or co-makers
Concealing the collector’s true identity

Outsourcing collection does not automatically free the lending or financing company from responsibility for its agent’s conduct.

Consumer protection for banks and other financial service providers

Republic Act No. 11765, the Financial Products and Services Consumer Protection Act of 2022, prohibits abusive debt-collection and recovery practices by covered financial service providers. It also requires consumer-assistance mechanisms and makes providers responsible for the conduct of their agents, with potential solidary liability involving accredited third-party service providers. (Supreme Court E-Library)

Privacy and public shaming

Using a borrower’s personal data to contact unrelated persons, expose the debt publicly, access phone contacts without a lawful basis, or shame the borrower online may raise issues under Republic Act No. 10173, the Data Privacy Act of 2012. The National Privacy Commission has specifically addressed abusive online-lending practices involving contact harvesting and public disclosure. (National Privacy Commission)

Civil liability for abusive conduct

Articles 19, 20, and 21 of the Civil Code require people to act with justice, give everyone their due, and observe honesty and good faith. Conduct that willfully causes loss or injury contrary to law, morals, good customs, or public policy may support a claim for damages in appropriate circumstances. (Lawphil)

Where complaints may be filed

Institution	Appropriate concerns	Official channel
Original creditor or financial institution	Incorrect balance, unauthorized collector, disputed debt, abusive collection	Institution’s consumer-assistance or complaint unit
Bangko Sentral ng Pilipinas	Complaints involving BSP-supervised banks and financial institutions after using the institution’s complaint process	BSP Online Buddy
Securities and Exchange Commission	Lending companies, financing companies, and SEC-regulated online lending platforms	SEC iMessage complaint portal
National Privacy Commission	Unauthorized disclosure, contact harvesting, data misuse, public shaming, or privacy violations	NPC complaint procedures
Police, NBI, or cybercrime authorities	Forged court documents, phishing, identity theft, extortion, impersonation, or theft of account credentials	Appropriate law-enforcement or cybercrime office

The BSP, SEC, and NPC each maintain their own complaint procedures and jurisdictional requirements. Keep the original email, attachments, proof of identity, account documents, prior correspondence, and evidence that you first raised the matter with the regulated institution when required. (Bureau of Small and Medium Enterprises)

Can You Be Arrested Because of an Unpaid Debt?

The 1987 Constitution expressly provides that no person shall be imprisoned for debt or nonpayment of a poll tax. An ordinary failure to pay a loan, credit-card balance, or civil judgment does not by itself authorize arrest or imprisonment. (Lawphil)

This does not protect a person from prosecution for a separate criminal act. Depending on the evidence, offenses such as fraud or estafa may be investigated. Issuing a dishonored check may also lead to a case under Batas Pambansa Blg. 22 when its legal elements are present. The criminal case would be based on the alleged offense—not merely on the existence of an unpaid debt. (Lawphil)

A collector who says “pay today or you will automatically be arrested for debt” is therefore making a materially misleading statement.

Common Real-Life Scenarios

“The collector says my bank account will be levied tonight”

Without a case, court order, writ, and sheriff’s garnishment served on the bank, the statement is generally a collection threat rather than a completed levy.

However, a creditor that already obtained a judgment may seek garnishment without first negotiating with you again. Verify the court case rather than relying on the collector’s wording.

“My bank account is already frozen, but I only learned through email”

Contact the bank immediately and obtain the court, case, creditor, sheriff, date, and amount shown in the garnishment notice. A bank restriction is more significant evidence of actual garnishment than the collector’s email alone because garnishment is implemented through service on the institution holding the funds.

“The sheriff levied property owned by my parent, spouse, landlord, or employer”

Execution generally reaches the judgment debtor’s property, not property owned exclusively by another person. The true owner should gather proof of ownership and evaluate a third-party claim or appropriate court remedy.

Property relations between spouses may require closer examination because an asset may be exclusive property, community property, or conjugal partnership property, and liability may depend on who incurred the obligation and whether the family or property regime benefited.

“The email says my family home is not protected”

Family-home protection is fact-dependent. The creditor’s statement is not conclusive, but neither is the debtor’s bare assertion that the property is a family home. Ownership, actual residence, the date and nature of the debt, any mortgage, and the Family Code exceptions must be examined.

“I live abroad and received the notice by email”

A Philippine court may enforce a valid Philippine judgment against property or accounts located in the Philippines even when the debtor is abroad, provided jurisdiction and procedural requirements were satisfied.

A private collector cannot unilaterally levy assets in another country. A foreign judgment also does not automatically operate as a Philippine writ of execution. Under Rule 39, a foreign judgment against a person is generally treated as presumptive evidence of a right and may be challenged for lack of jurisdiction, lack of notice, collusion, fraud, or clear mistake of law or fact. Philippine recognition or enforcement proceedings may be necessary. (Supreme Court E-Library)

An overseas Filipino or foreign national appointing a Philippine representative may need a special power of attorney. Depending on where it is executed and how it will be used, it may need notarization by a Philippine embassy or consulate or an apostille from an Apostille Convention country. (Philippine Embassy in New Delhi)

Frequently Asked Questions

Can a debt collector levy my bank account without a court order?

For an ordinary private debt, a collector cannot independently levy or garnish your bank account. Garnishment normally requires valid court process and service by the sheriff or proper officer on the bank. Contractual set-off by the bank itself is a different issue and may depend on your account and loan agreements.

Is an emailed notice valid if it was signed by a lawyer?

A lawyer’s signature may make the communication a formal legal demand, but it does not turn the document into a court-issued writ or a sheriff’s levy. Verify the case, judgment, writ, and sheriff separately.

Can the debt collector send a sheriff to my house?

A sheriff may visit to implement a valid court writ. A private collector cannot simply hire someone, call that person a sheriff, and seize property. Ask for official identification, the original or authenticated writ, the court branch, and the case number.

What if I never received a summons?

Do not assume the judgment is automatically void, because the court record may show personal service, substituted service, service outside the Philippines, publication, or another court-authorized method. Obtain the summons, sheriff’s return, affidavits, and orders concerning service. Lack of valid service can be a serious jurisdictional issue, but it must be evaluated against the actual record.

Can my salary be garnished?

Certain compensation or credits may be reached through garnishment, but Rule 39 exempts wages necessary for the support of the debtor’s family during the four months preceding the levy. The exemption is fact-specific and may require proof of the source of the money and its necessity for family support.

Can the sheriff take all my household belongings?

No. Rule 39 exempts various necessities, including specified clothing, household furniture and utensils, food provisions, tools used for livelihood, and professional equipment, subject to statutory limits and exceptions. Luxury items and property not reasonably necessary may be treated differently.

Can my family home be sold for a credit-card or loan judgment?

A qualifying family home is generally protected, but the exemption is not automatic in every case. The date of the debt, ownership, residence, mortgage status, nature of the obligation, and exceptions under Article 155 of the Family Code must be examined.

Can a bank freeze my account before notifying me personally?

A bank may act after receiving a facially valid garnishment notice from the sheriff. The garnishment is directed to the bank as the holder of the debtor’s funds, so the account restriction may occur before the debtor personally sees the creditor’s email.

What if the debt is not mine?

Notify both the collector and alleged creditor in writing that you dispute the account. Request the application, contract, identification documents, disbursement records, transaction history, and proof connecting you to the debt. Preserve evidence of identity theft and report forged documents, unauthorized accounts, or misuse of personal information to the appropriate institution and authorities.

Does ignoring the email make the levy invalid?

No. A fake email does not become valid because you respond, but genuine court process does not become invalid merely because you ignore it. Verification is safer than either immediate payment or complete inaction.

Key Takeaways

An email from a private debt collector does not, by itself, create a legal levy.
A genuine levy normally requires a valid judgment or court order, a court-issued writ, and implementation by a sheriff or proper officer.
Email may be a legally recognized method of communication or electronic service, but it cannot replace the substantive acts required to levy property.
Verify the court, case number, judgment, writ, sheriff, creditor, amount, and affected property through independent official channels.
Do not pay through personal accounts, disclose an OTP, or surrender property to anyone who cannot prove official authority.
Court remedies can be extremely time-sensitive, especially after garnishment or before a sheriff’s sale.
Debt collection is lawful; impersonation, fabricated levies, public shaming, deceptive threats, and abusive collection practices are not.