Guzman Ayala, Ricardo

Applicant Ricardo Guzman Ayala settled his claim via a Compromise and Release for $42,500, with terms waiving penalties and interest if payment was made within 30 days of receipt of the OAC&R. Defendant issued the settlement check but sent it to applicant's prior address (his official address of record), despite a handwritten address change on the C&R. Applicant received the check 14 days after it was due and 7 days after defendant was notified of the delay. The WCJ found no unreasonable delay and denied Labor Code section 5814 penalties. On reconsideration, the Board agreed there was no unreasonable delay but rescinded and substituted the F&O to clarify the reasoning and remove the finding that applicant's conduct contributed to the delay.