Not upheld: irresponsible lending and unaffordable credit complaint against Vanquis Bank Limited

Decision detail

Summary

Miss B complained that Vanquis Bank Limited provided her with an unaffordable credit card and failed to intervene when she showed signs of financial difficulty. The complaint was made in October 2025, more than six years after the initial lending decision in 2009. The ombudsman considered the complaint under section 140A of the Consumer Credit Act 1974 regarding unfair credit relationships. The ombudsman found that Vanquis's initial lending checks were reasonable, and that while the 2013 and 2014 credit limit increases lacked detailed financial checks, bank statement evidence suggested Miss B had sufficient disposable income to afford them. The ombudsman also found that Vanquis engaged with Miss B about her account use and took mitigating action by reducing her credit limit in 2017 when she began experiencing difficulties. The complaint was not upheld.

The Ombudsman's reasoning

The ombudsman applied section 140A of the Consumer Credit Act 1974 to assess whether the relationship was unfair. For the initial credit limit, the checks were reasonable given the terms of credit and Miss B's financial situation at the time. For the 2013 and 2014 limit increases, while the checks were not fully detailed, the ombudsman reviewed Miss B's bank statements and concluded that reasonable checks would have shown Miss B had sufficient disposable income to afford the increases. The ombudsman found that Vanquis did engage with Miss B about her account use and took mitigating action by reducing her credit limit to £100 in February 2017 when she began experiencing difficulties from mid-2016 onwards. The ombudsman noted that persistent debt rules only came into effect in 2018 and Miss B's account management from 2018 onwards would not have triggered identification as persistent debt.

How this compares

Source

Read the original decision on the Financial Ombudsman Service website