What can a business do to protect itself from a debtors attempt to create an accord and satisfaction by sending the creditor a check with paid in full written on it?

• Nothing. Businesses must carefully review every check to avoid inadvertently creating an accord and satisfaction.

• Issue only liquidated debts to debtors and include provisions in credit card statements prohibiting the issuance of unliquidated debt.

• Rely on the doctrine of promissory estoppel to ensure such checks are not valid.

• Notify debtors that any attempt to settle a claim for less than the amount owed must be sent to a particular address and/or a particular person.

• Sue the debtor for the remaining balance and argue there was insufficient consideration because there was no bargained-for exchange when the check was sent Paid in Full.