an agreement to buy the land, or show "common intention" by jointly contributing to the price or mortgage of a property, as in Lloyds Bank plc v Rosset. Second, when a contract to transfer rights is agreed to, the equitable interest is automatically transferred, something that also applies to personal property. Third, a constructive trust may be created where there are several parties interested in commercially exploiting land, and some refrain from doing so due to an agreement with the defendant, as in Pallant v Morgan. In Banner Homes Group plc v Luff Developments Ltd, it was decided that this principle applies even when no binding contract has been signed, and the claimant has refrained due to ongoing negotiations with the defendant. Another "more contentious" form of constructive trust is in a situation where the claimant has "done everything necessary". Where the owner of property intends to transfer property to another, completes their side of the transfer and the transfer then fails, this property is held on constructive trust as in Re Rose. In relation to personal property, a constructive trust is created over a fund created to protect pre-payments to a company in the event of that company going into insolvency. In several situations, companies, knowing they are in dire financial straits, have put money paid to them by customers for products not yet delivered in a separate bank account to protect it in the event of insolvency. This causes theoretical problems; it is "difficult to square the conscionability of holding the money on trust for the customers with the pari passu principle in insolvency law that no unsecured creditor should be given an advantage over any other unsecured creditor". Profits from unlawful acts Where acts lead to profit and are illegal, under either English criminal law or an established legal principle, equity puts any property acquired through these acts into a constructive trust. The most common type of trust here is one resulting from bribery; where somebody in a fiduciary office makes unlawful profit, that money is held on constructive trust for the beneficiaries of his office. In Attorney General for Hong Kong v Reid, the Director of Public Prosecutions in Hong Kong accepted bribes to not prosecute certain people. The court held that this was a violation of fiduciary duty, and put the money on constructive trust. An issue with this principle is that the position of