Financial Ombudsman Service decision
DRN-6284419
The verbatim text of this Financial Ombudsman Service decision. Sourced directly from the FOS published decisions register. Consumer names are reduced to initials by FOS at point of publication. Not an AI summary, not a paraphrase — every word below is the original decision.
Full decision
The complaint Miss B complains that PROPEL HOLDINGS (UK) LIMITED trading as Quidmarket (Quidmarket) gave her loans she couldn’t afford to repay. What happened Miss B’s borrowing history can be found below. loan number loan amount agreement date repayment date loan term (months) highest repayment per loan 1 £500 05/12/2023 19/07/2024 6 £150.25 2 £400 14/10/2024 27/12/2024 3 £211.36 break in lending 3 £400 14/10/2025 20/10/2025 3 £185.66 4 £500 16/01/2026 outstanding 3 £224.95 Quidmarket reviewed the complaint and didn’t uphold it. Miss B then referred the complaint to the Financial Ombudsman where it was considered by an Investigator. The Investigator also didn’t uphold the complaint and Miss B didn’t agree with the outcome. As no agreement could be reached the complaint has been passed to me for a decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. We’ve set out our general approach to complaints about short-term lending - including all the relevant rules, guidance and good industry practice - on our website. Quidmarket had to assess the lending to check if Miss B could afford to pay back the amounts she’d borrowed without undue difficulty. It needed to do this in a way which was proportionate to the circumstances. Quidmarket’s checks could have taken into account a number of different things, such as how much was being lent, the size of the repayments, and Miss B’s income and expenditure. With this in mind, I think in the early stages of a lending relationship, less thorough checks might have been proportionate. But certain factors might suggest Quidmarket should have done more to establish that any lending was sustainable for Miss B. These factors include: • Miss B having a low income (reflecting that it could be more difficult to make any loan repayments to a given loan amount from a lower level of income); • The amounts to be repaid being especially high (reflecting that it could be more difficult to meet a higher repayment from a particular level of income);
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• Miss B having a large number of loans and/or having these loans over a long period of time (reflecting the risk that repeated refinancing may signal that the borrowing had become, or was becoming, unsustainable); • Miss B coming back for loans shortly after previous borrowing had been repaid (also suggestive of the borrowing becoming unsustainable). There may even come a point where the lending history and pattern of lending itself clearly demonstrates that the lending was unsustainable for Miss B. But given the amounts lent and the borrowing was in two lending chains then this doesn’t apply to Miss B’s complaint. Quidmarket was required to establish whether Miss B could sustainably repay the loans – not just whether she technically had enough money to make her repayments. Having enough money to make the repayments could of course be an indicator that Miss B was able to repay her loans sustainably. But it doesn’t automatically follow that this is the case. Miss B has in response to the view questioned the help and support provided by Quidmarket once she told them about her change in circumstances which has led to repayment problems on the final loan This wasn’t addressed as part of the original complaint and so Quidmarket hasn’t had the chance to investigate this point. As such, I won’t be looking at this further. But Miss B is free to raise her concerns directly with Quidmarket and then refer the complaint here if she is unhappy with the response provided. Loans 1 and 2 Miss B told Quidmarket she received an income of no more than £1,700 per month. Quidmarket didn’t just rely on what Miss B said – it cross checked the income with a tool widely used within the industry. Quidmarket didn’t make any adjustments to Miss B’s income for either loan and so it was satisfied that what she declared was likely accurate. For the first loans, I think this check was proportionate. In terms of outgoings, Miss B said she lived at home with parent(s) – and so Quidmarket wouldn’t have expected her to have had the same sort of priority debts that someone who had a mortgage or was in rented accommodation and would. And it would explain the low declared level of Miss B’s outgoings. Miss B declared outgoings of no more than £210 per month. Quidmarket then went about checking the information Miss B had provided along with conducting a credit search – which I’ll come on to below. Having carried out checks into the information Miss B had provided it uplifted the monthly costs for both loans, for example to £563 per month at loan two. This left enough disposable income to cover the payments Miss B was committed to making. Quidmarket also carried out credit searches and it has provided the results it received. The results didn’t show any types of insolvency, defaults or County Court Judgements. All of Miss B’s existing accounts had been managed as expected with no missed payments or signs she was in arrears or financial difficulties. Her debt had increased between loans 1 and 2 but this was as a result of taking out a new hire purchase agreement in March 2024 – which had been repaid as expected by the time of loan 2. The credit check results wouldn’t have led to further checks or to Quidmarket declining the application. It did take Miss B slightly longer to repay loan 1 than expected, and this was due to Quidmarket offering forbearance when Miss B told it she was having some health problems. That seems reasonable to me, and there was then a small gap before loan 2, where she
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borrowed a smaller sum. The problems with loan 1, wouldn’t have impacted Quidmarket’s decision to lend loan 2. As such, given the rest of the checks that Quidmarket carried then the decision to provide these loans was fair because proportionate checks were made which showed the loans were affordable. I do not uphold Miss B’s complaint about the lending decision for these loans. Loans 3 and 4 There was a gap of around 9 months after Miss B repaid loan 2 and before she returned for the first loan in this chain of borrowing. I think this break in borrowing was sufficient for the lending chain to in effect reset. This means loan 3 became loan 1 of a new chain and Miss B could be treated as if she was a brand-new customer. This also has implications for the level and types of check we consider to have been reasonable for Quidmarket to have carried out to have fulfilled its obligation to do a proportionate check. I won’t go into as much detail for these loans because in the final response letter and the assessment by the Investigator it set out the information provided by Miss B and what the checks showed Quidmarket. But in summary, it carried out the same checks for these loans as it had done so for loans 1 and 2. So, Miss B’s declared income was cross checked using the same tool from the credit reference agency. This time for both loans Miss B’s income was decreased to no more than £2,250 per month. This check was proportionate. Quidmarket then took details of Miss B’s outgoings which were then crossed check. And even when Quidmarket made adjustments to these figures it still left Miss B with sufficient disposable income with which to afford the repayments, he had committing to making. Most of this adjustment was as a result of Miss B declaring that she was now in private rented accommodation. Quidmarket has provided the credit file data for each of these loans, and I’ve considered what it saw. There wasn’t anything that would’ve led Quidmarket to be overly concerned. Both reports showed no CCJs, insolvencies, defaults or missed payments and I think it’s fair to say that both reports also indicated Miss B had a modest level of overall debt of no more than £1,400. Miss B appeared to be managing her repayments as expected with no signs that she was having or likely having financial difficulties. As such, the credit searches wouldn’t have prompted further checks or led Quidmarket to decline her applications. It therefore follows that I don’t think Quidmarket needed to have verified any of the information more closely than it did. As such, I wouldn’t have expected it to have gathered bank statements for these loans. Overall, for these loans I’m satisfied the checks were proportionate which demonstrated Miss B would be in a position to afford these loans. As such I am not upholding his complaint. An outstanding balance does remain on loan 4, and I would remind Quidmarket of its obligation to treat Miss B fairly and with forbearance. I’ve also considered whether the relationship might have been unfair under Section.140A of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Quidmarket lent irresponsibly to Miss B or otherwise treated her unfairly in relation to this matter. I haven’t seen anything to suggest that Section 140A would, given the facts of this complaint, lead to a different outcome here.
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My final decision For the reasons set out above, I am not upholding Miss B’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss B to accept or reject my decision before 26 May 2026. Robert Walker Ombudsman
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