Facing a DPN? Remember, the 21-day clock starts on the actual issue date, not...

https://victor-wiki.win/index.php/Director_Penalty_Notices:_Defining_%22Reasonable_Steps%22_and_Surviving_the_21-Day_Clock

Facing a DPN? Remember, the 21-day clock starts on the actual issue date, not upon client receipt. Correctly distinguishing between lockdown and non-lockdown penalties is critical to providing sound advice, so you can triage fast and keep options open.