 The effect of the "SAAMCO" case was to exclude from liability the damages attributable to a fall in the property market notwithstanding that those losses were foreseeable in the sense of being “not unlikely” (property values go down as well as up) and had been caused by the negligent valuation in the sense that, but for the valuation, the bank would not have lent at all and there was no evidence to show that it would have lost its money in some other way.It was excluded on the ground that it was outside the scope of the liability which the parties would reasonably have considered that the valuer was undertaking.Subsequent case law has drawn a distinction between cases merely providing information, and those providing advice.