Not upheld: Irresponsible lending complaint against Lendable Ltd trading as Zable

Decision detail

Summary

Mrs W complained that Zable acted irresponsibly by lending to her when she was struggling financially with high existing debt. She received a credit card in July 2023 with a £200 limit, increased to £500 in October 2023 and £1,000 in March 2024. The ombudsman found that Zable carried out proportionate checks at each stage, verified Mrs W's income, used reasonable estimates for living expenses, and found substantial disposable income remaining. CRA data showed Mrs W was managing her existing credit well with no recent missed payments despite historical defaults, and the ombudsman concluded the lending decisions were fair and affordable. The complaint was not upheld.

The Ombudsman's reasoning

The ombudsman applied the regulatory requirement for proportionate checks considering the type, amount, duration and total cost of credit, and the borrower's circumstances. At account opening, Zable had verified income, known housing costs, and CRA data showing low existing indebtedness and recent good credit management despite historical defaults. The use of ONS estimates for living expenses was reasonable given the large disposable income remaining (£1,160) and the very low initial credit limit. For the increases, CRA data showed no missed payments, improved credit scores, and manageable credit commitments with substantial remaining disposable income (approximately £2,000). The ombudsman found no evidence of financial difficulty at the time of lending decisions.

How this compares

Source

Read the original decision on the Financial Ombudsman Service website