DRN-6286937

The complaint Mr C complains that PROPEL HOLDINGS (UK) LIMITED trading as Quidmarket (Quidmarket) gave him loans without carrying out sufficient affordability checks. What happened A summary of Mr C’s borrowing can be found below. loan number loan amount agreement date repayment date number of monthly repayments monthly repayment amount 1 £500 13/08/2025 05/01/2026 5 £191.40 2 £1,000 20/01/2026 outstanding 5 £328.32 Following Mr C’s complaint, Quidmarket explained why it had carried out proportionate checks. The complaint was then referred to the Financial Ombudsman, and it was reviewed by an Investigator. They didn’t uphold the complaint because they were satisfied Quidmarket had carried out sufficient affordability checks. Mr C didn’t agree and I’ve summarised his response below. • When loan 2 was provided Mr C already had several outstanding payday loans. • It wasn’t reasonable to have relied on the declared income and expenditure. • Had better checks been made Quidmarket would’ve seen Mr C was reliant on short term loans and was gambling. As no agreement could be reached the complaint has been passed to an me, an Ombudsman for a final 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. The basis for what I go on to discuss below is laid out in CONC 5.2A and Quidmarket had to assess the lending to check if Mr C could afford to pay back the amount he’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 Mr C’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 Mr C. These factors include:

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• Mr C 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); • Mr C 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); • Mr C 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 Mr C. But I don’t think that would apply here because only two loans were granted. Quidmarket was required to establish whether Mr C could sustainably repay the loans – not just whether he technically had enough money to make his repayments. Having enough money to make the repayments could of course be an indicator that Mr C was able to repay his loans sustainably. But it doesn’t automatically follow that this is the case. Quidmarket asked Mr C about his income and expenditure. Mr C declared he received a monthly salary of £2,350 for loan 1 and £2,850 per month for loan 2. Quidmarket didn’t just accept what Mr C declared, instead it electronically cross checked these amounts but it didn’t make any adjustments. Indicating it was content to rely on what it was told. I’m satisfied Quidmarket didn’t just rely on Mr C’s declaration for its affordability assessment and for the first loans this was a proportionate check. In terms of outgoings – which included existing credit commitments, Mr C declared these came to £544 per month for loan 1 and £450 for loan 2. The outgoings may have seemed a little low, but Mr C declared that he lived at home with parents and so Quidmarket wouldn’t have expected him to have the same sort of priority bills as say someone with a mortgage or in rented accommodation. The small monthly outgoings wouldn’t have been overly concerning. However, Quidmarket made checks into Mr C’s outgoings including his credit commitments and it increased the amount he thought Mr C spent each month. Based on its calculations, Quidmarket believed Mr C’s outgoings came to £929 for loan 1 and £977 for loan 2. Even with the smaller disposable income, it was still reasonable for Quidmarket to believe Mr C would be able to afford the loan payments. As I said, a credit search was also carried out and Quidmarket has provided a copy of the results it received. It’s worth saying here that there was, and is, no requirement for Quidmarket to do a credit search nor is there any set standard it has to adhere to. I’ve therefore looked at these to see if there was anything contained within the results which ought to have either led Quidmarket to have conducted further checks and or to have declined the application. The credit searches were carried out at the address that Mr C declared as part of his application and there wasn’t anything there to suggest that Mr C was having or likely having financial difficulties. Both of the credit search results didn’t show any signs of financial difficulties, there were no defaults, delinquencies, insolvencies or County Court Judgements recorded. Mr C has recently provided a copy of a screen shot showing a default from March 2023. This default wasn’t in the results received by Quidmarket. But even if it was, and Quidmarket had

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known about it, given the default had occurred more than two years before the first loan, I don’t think Quidmarket would’ve been prompted to carry out further checks given the lack of recent adverse payment information. I don’t think the default from 2023 was a sign that at the time Mr C was or was likely having difficulties. The total outstanding debt did increase slightly between loans 1 and 2 but that seems to have been because of Mr C opened a new hire purchase agreement in September 2025. Quidmarket was aware of this and so wouldn’t have led it to conduct any further checks. Mr C has helpfully provided a list of loans that he had taken from other payday lenders at around the time (and in between) these loans. Some of these loans are present in the search results given to Quidmarket. But some aren’t. For example, Mr C has said he took a payday loan at the start of January 2026 – but that record wasn’t visible in the credit search results for loan 2. This is mainly because it can take up to eight weeks for a lender to update the credit file so there can be a delay between new accounts opening and when they are reported to the credit reference agencies. However, while the credit results do show that Mr C had other loans active at the time, given the number of loans he’s taken from Quidmarket, and the checks indicated these loans were affordable, I don’t think the sight of other loans, is enough to say the complaint ought to be upheld. Looking at the credit reports provided Quidmarket – based on the caveats above were entitled to rely on what it was provided didn’t indicate Mr C was, or was likely to be, having financial difficulties at the time. I also don’t think Quidmarket ought to have gathered or reviewed Mr C’s bank statements. I’ve considered this but given the checks Quidmarket did do, these were commensurate to the amounts lent and what it knew about Mr C. Taking account of the circumstances of the complaint, it would’ve been disproportionate for Quidmarket to have gathered and reviewed Mr C’s bank statements. As such Quidmarket didn’t or couldn’t have known about Mr C’s gambling. This means I can’t uphold the complaint for this reason. Overall, Quidmarket carried out a proportionate check which showed Mr C would likely be in a position to afford his repayments. I appreciate this outcome will be disappointing for Mr C. An outstanding balance is still likely due, and Mr C may wish to, if he hasn’t already done so to contact Quidmarket to see what help and support it can offer moving forward. I would remind Quidmarket of its obligation to treat Mr C fairly and with forbearance. I’ve also considered whether the Quidmarket acted unfairly or unreasonably in any other way and whether the relationship might have been unfair under Section140A of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Quidmarket lent irresponsibly to Mr C or otherwise treated him 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. My final decision For the reasons I’ve outlined above, I am not upholding Mr C’s complaint.

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Under the rules of the Financial Ombudsman Service, I’m required to ask Mr C to accept or reject my decision before 26 May 2026. Robert Walker Ombudsman

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