Partially upheld: irresponsible lending - failure to conduct adequate affordability assessment complaint against Savvy Loan Products Limited trading as Tick Tock Loans
Financial Ombudsman decision DRN-6173989 of 2026-04-24T00:00:00+00:00. irresponsible lending - failure to conduct adequate affordability assessment complaint against Savvy Loan Products Limited trading as Tick Tock Loans. Outcome: Partially upheld.
Decision detail
| Reference | DRN-6173989 |
|---|---|
| Decision date | 2026-04-24T00:00:00+00:00 |
| Firm | Savvy Loan Products Limited trading as Tick Tock Loans |
| Product | payday loan |
| Claim type | irresponsible lending - failure to conduct adequate affordability assessment |
| Outcome | Partially upheld |
| Remedy | Tick Tock must: (A) Calculate total repayments made by Mr J towards interest, fees and charges on loan 3; (B) Calculate 8% simple interest on individual payments from date of payment to settlement date; (C) Pay Mr J the total of (A) plus (B); (D) Remove any adverse information about loan 3 from Mr J's credit file. |
Summary
Mr J complained that Tick Tock Loans lent to him irresponsibly without conducting sufficient affordability checks, particularly given his repeat borrowing and gambling. He took out three payday loans between January and November 2024. The ombudsman found that loans 1 and 2 were granted with proportionate checks showing sufficient disposable income and no clear financial difficulties. However, for loan 3, Tick Tock had access to open banking data showing Mr J was making regular transfers of at least £999 monthly to gambling-related accounts, in addition to existing credit commitments of £686 monthly. The ombudsman upheld the complaint regarding loan 3, finding Tick Tock should have treated these transfers as regular outgoings, making the loan unaffordable. Tick Tock was ordered to refund interest, fees and charges with 8% simple interest and remove adverse credit file information.
The Ombudsman's reasoning
For loans 1 and 2, proportionate checks were carried out including verification of income via payslips, assessment of outgoings using credit file data and national averages, and credit searches. The checks showed sufficient disposable income and no clear indicators of financial difficulty. However, for loan 3, Tick Tock had access to open banking data showing Mr J was making regular substantial transfers (at least £999 per month) to what appeared to be gambling-related accounts, in addition to his existing credit commitments totalling £686 per month. The ombudsman concluded these transfers should have been treated as regular outgoings, making the loan unaffordable. Even if the transfers were not conclusively gambling-related, their regular nature meant they would likely continue and impact affordability. Tick Tock could not rely on the assumption that Mr J would cease these transfers to afford the new loan.
How this compares
| Group | Decisions | Uphold rate |
|---|---|---|
| Savvy Loan Products Limited trading as Tick Tock Loans, all decisions | 3 | 33% |
Source
Read the original decision on the Financial Ombudsman Service website