The co-editors of www.FamilyArbitrator.com have devised a comprehensive checklist of topics and considerations for discussion at the First Directions Appointment. This is usually the first stage once an IFLA family financial arbitration is commenced. Prior to the meeting, the parties are invited to fill in what is in effect a Scott Schedule for exchange, on an informal basis, both so that common ground can be established and to clarify where issues may arise that will need determination at that meeting.

The checklist may also however give those unfamiliar with an IFLA arbitration a good understanding of the options which are available and the extent to which the parties can influence the procedure they would like adopted for the resolution of their dispute.

What follows is a list of what we think are the most important and instructive questions, which both illustrate the nature of the process and underline its pragmatic flexibility.

1. Please confirm that there are no outstanding issues or questions as to the terms and conditions of your arbitrator's appointment.
2. Have any allegations of violence or significantly oppressive conduct been made by either party which may affect the suitability of the matter to be dealt with by arbitration?
3. Meetings and hearings are ordinarily held with both parties together. Does this create any concerns for you?
4. Do you have any special requirements and/or disability of which the arbitrator should be made aware?
5. Any there any particular points in the IFLA Rules which you wish to suggest might be amended or qualified for the purposes of this arbitration (save for Art 3 which immutably requires that the arbitrator should apply the law of England and Wales)?
6. If the arbitrator has disclosed any actual or potential conflict of interest or any matter that might give rise to justifiable doubts as to his or her impartiality do you waive any objection or do you wish him to stand down?
7. Which party should be designated as the lead party in the arbitration?
8. Please confirm the mode of communication between meetings that you prefer (email 'to all' is the arbitrator's preference). 
9. Should the other party provide security for fees and expenses?
10. Do you consider that there are any aspects of the dispute (or indeed the whole arbitration) that may be appropriate for a cap on recoverable costs?
11. Save for the Form ARB1 [the formal arbitration agreement], have you agreed anything in writing which affects the procedure for the arbitration?
12. Do you wish the arbitrator to have the authority to record any agreements reached at the preliminary and subsequent meetings on your behalf?
13. Are you content that the issue/s to be determined by this arbitration are clearly identified in the Form ARB1? If not, please append any alternative draft for discussion.
14. Do you have any other points of concern or procedural/case management issues that need to be raised at first meeting?
15. If you have been or currently are engaged in legal proceedings concerning the same dispute, briefly state their nature, the stage reached, and the date of the next hearing if any has been fixed.
16. If you are currently involved in any other kind of dispute resolution (mediation or round table discussions) then, without disclosing anything relating to the negotiation, has that process come to an end or do you hope to resume it at a later stage?
17. Preferred mode of convening interim meetings: in person, by telephone (conference call), or Skype?
18. Do the issues suggest that any other person, company or trust should be invited to join the arbitration?
19. What procedure should be adopted for the arbitration, ie Art 10 [a framework akin to fast-tracking under the CPR] or Art 12 [an alternative more in line with the FPR, Part 9] or some adaptation?
20. If Art 10 is to be followed, are written statements of claim and defence to be prepared? If so, in what sequence and by when? What form should they take: e.g. pleadings, or statements with evidence exhibited?