Evergreen Finance London Limited · DRN-6211523

The complaint Mrs S complains that Evergreen Finance London Limited trading as MoneyBoat.co.uk (“MoneyBoat”) lent to her when she had too much other debt and was in a debt spiral. She considers it was irresponsible. What happened Mrs S took three loans with MoneyBoat and here is a table showing the lending decisions. Loan Approved Amount Terms (rounded) Repaid 1 2 November 2022 £500 £239 a month for 3 months 16 November 2022 Significant gap of a period approaching three years 2 10 August 2025 £500 £172 a month for 5 months 5 September 2025 3 30 September 2025 £800 £264 a month for 6 months o/s Loan 3 has not been paid off and Mrs S is paying £1 a month to MoneyBoat as a token payment. After Mrs S had complained and received the final response letter (FRL) from MoneyBoat in late January 2026, she referred it to us and one of our investigators did not think that MoneyBoat needed to do anything to put things right. Mrs S disagreed and gave reasons why. The unresolved complaint was passed to me to decide. I am conscious that Mrs S will recognise that I have been presented with two of her complaints and I have reviewed them at the same time. The loans taken with this lender and the other lender on the other complaint intermingle to an extent. One of the differences with this one is that at Loan 3 MoneyBoat would not have seen the other lender’s Loan 3 (£1,500 issued on 5 September 2025) as it had not registered on the credit search. I raise this at the beginning as Mrs S will be receiving these two decisions from me at the same time. 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. MoneyBoat needed to make sure that it didn’t lend irresponsibly. In practice, what this means is that it needed to carry out proportionate checks to be able to understand whether any lending was sustainable for Mrs S before providing it. Our website sets out what we typically think about when deciding whether a lender’s checks were proportionate. And I’ve used this approach to help me decide her complaint.

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Generally, we think it’s reasonable for a lender’s checks to be less thorough – in terms of how much information it gathers and what it does to verify that information – in the early stages of a lending relationship. But we might think it needed to do more if, for example, a borrower’s income was low, the amount lent was high, or the information the lender had – such as a significantly impaired credit history – suggesting the lender needed to know more about a prospective borrower’s ability to repay. My first observations are that Loan 1 was for a relatively modest sum and then there was a very long gap before Mrs S approached MoneyBoat again for a similarly modest sum. These are all relevant elements to the lending relationship which I’m being asked to look at. The significant gap means that we do not consider MoneyBoat would’ve acted unreasonably by considering that Loan 2 was effectively as if Mrs S was a new customer. And the value of Loans 1 and 2 being ‘first loans’ mean that the proportionate checks we’d expect MoneyBoat to carry out to comply with the regulations were, within context, loans where we’d not expect a full review of Mrs S’ financial circumstances to take place. It was acting reasonably to rely on the information Mrs S gave to MoneyBoat when approaching it for credit. I’ve reviewed what checks MoneyBoat carried out for each loan. Income Mrs S has made submissions surrounding her income and said that the declared figure in 2022 of £3,000 a month (after tax) and in 2025 of £3,700 and £3,800 were not her ‘base salary’ figures. Mrs S explains that her base salary was £2,750 each month and the additional sums received were commission, and overtime. However, I note that Mrs S has not said that she did not receive that income in those periods – but rather that MoneyBoat ought to have used a different figure to the one she had said it was. But MoneyBoat has explained that it used Credit Reference Agency (CRA) data to check the income and if it was unable to obtain that it would have asked Mrs S for other evidence such as payslips. As no copy payslips have been sent to us, I deduce that MoneyBoat obtained the confirmations it needed of Mrs S’ income into her account as being around the figures she had declared to it in 2022 and in 2025. And I am satisfied with that. The two strands of evidence which lead me to be satisfied are that MoneyBoat checked with CRAs and did not need to ask for more evidence from Mrs S, and Mrs S has not denied receiving the other income on top of the base salary. Her view is that it ought to have used a different figure to the one she supplied. And I disagree. I have applied this logic in respect of the income for each of the three loans. Rent/mortgage For each of these loans Mrs S had declared £0 for it. The MoneyBoat CRA checks do not reveal a mortgage commitment. Having reviewed another complaint I have seen that the likely explanation was that the mortgage documents were in the name of Mrs S’ former husband. Mrs S has explained that she was expected to pay for 50% of that mortgage but MoneyBoat would not have been expected to have known of that unless Mrs S had informed it at the time – but I’ve received no evidence of that. And as I show later in the decision, Mrs S had enough to pay for any commitment for housing as well as repay the loans. Loan 1 Mrs S had underdeclared the outgoings for rent, and credit. I say that because Mrs S has said her rent was £0. I have answered that in part in the earlier paragraphs. And I have a copy of the credit search MoneyBoat did and I’ll come on to that later in the decision. But what I say at this point is that her monthly credit commitment costs were higher than the

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figure Mrs S had said (£225 a month). Mrs S’ other declared outgoings were for food (£175 a month) and ‘other’ (£350 a month). I reviewed the credit search report carried out by MoneyBoat on 2 November 2022. There were no adverse repayment markers, no insolvency indicators, no delinquency or defaulted accounts and no judgment debts. Mrs S had an outstanding debt balance of over £27,000 of which £10,800 was the outstanding balance on a bank loan taken in 2018 for which she was repaying £289 a month. Mrs S also had several other smaller loans, two mail order accounts and a current account with a £2,000 overdraft the balance on which was £460. So, Mrs S was under her limit there. Mrs S’ loans were costing her £640 a month in total. Mrs S did have multiple credit cards – ten – and some were close to their limit. While, others were under their credit limits. But there are no records of any issues with repayments. Mrs S appeared to have had a cash flow issue by reading that credit report but that often is the reason a person applies for a loan to tide them over until the next salary credits the bank account. That in itself does not show a financial difficulties issue. As I said earlier in the decision, Mrs S declared credit commitment costs each month of £225 and reviewing that credit report, clearly she was spending more than that. For instance, her total revolving credit balance (for credit cards and mail order) was £11,879 and my view is that a 3% minimum charge each month is more realistic – I disagree with our investigator using 2%. So that translates into around £357 a month. Mrs S’ loans were costing her £640 a month. So, in my view, the total was around £997 a month. Add to that figure of £997, Mrs S’ declared costs for food, transport and ‘other’ then this all added up to around £1,547. When subtracted from her declared income of £3,000 then the disposable income was around £1,453 and Loan 1 would have been affordable together with any housing cost she likely was paying. And to see what its likely Mrs S would have told MoneyBoat had she been asked by it about her housing costs, I used the financial evidence Mrs S has sent in to see that she regularly paid a person with the same surname as her £370 a month in late 2022. That looks to have been the mortgage contribution. And I consider that on the figures Mrs S likely was able to afford it all and the loan as well. This was a very short term for a fairly modest sum and I consider that even if MoneyBoat had had a little more information from Mrs S still it would have been affordable. I do not uphold the complaint about Loan 1. Loan 2 Loan 2 was for £500 and was applied for two years nine months after repaying Loan 1, and Mrs S would have been treated as a new customer. I consider that approach by MoneyBoat fair and reasonable. Plus, a £500 loan application is a modest one. The main documentation I have from MoneyBoat is the credit search report it obtained in August 2025 which I have reviewed. Mrs S’ overall debt was £21,363 most of which was on revolving credit/budget accounts - £17,099. And as her limit for these types of account was £15,000 Mrs S was over her credit limit. It looks to have been the Budget Account she held which was over the limit. That £17,099 would have been costing her a minimum monthly repayment at 3% of around £513. Plus, there is a second reason that records can show ‘over the limit’ which I explain later in the decision. Mrs S’ loan commitment was £4,089. The bank loan she had been paying down three years ago was marked as delinquent but also being managed by her as it was in an arrangement to pay. Looking at the regular balance reductions that looked to have been set at around £377 a month. There was another loan costing her £194, so the total cost of her loans each month was around £571.

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£571 for all of Mrs S’ loans plus the £513 minimum repayment amount for the other kinds of accounts all added up to a total credit commitment cost each month of around £1,084. Mrs S had declared around £1,000 a month on her existing credit commitments. So that seems to have been about right. Since Mrs S had last been a customer of MoneyBoat she had received two defaults, both in February 2024. Both were credit cards and both were with Debt Collection Agents and Mrs S was reducing those default balances satisfactorily. Plus, they were 18 months before she applied to MoneyBoat for Loan 2. And so, I do not find it unreasonable that these defaults (being managed) were likely not a concern to it. And to explain to Mrs S, when a credit card is defaulted the limit level is usually reduced to £0 but as the balance is still recorded, the overall picture is of being ‘over the limit’ but that is a representation of the £0 limits for the defaulted accounts – not because of recent overspending on the ‘live’ cards. MoneyBoat had used the other figures Mrs S had declared and increased them a bit to make a total expenditure figure of around £905. This was made up of: £350 (food) + £300 (transport) + £100 (other) + £155 (the MoneyBoat increase). On a salary of £3,800 then Mrs S would have had £1,811 left to pay for whatever her housing cost was. As I said earlier in this decision, I can find a regular payment to a person with her surname and who was on the electoral roll at the property in the past. That was for £457 on 1 August 2025, So, this seemed to have been a regular contribution and therefore I am satisfied that if asked this would have been the figure Mrs S would have given to MoneyBoat. And so even if it had known this about her housing, then still I’d consider that MoneyBoat was being reasonable when it calculated Mrs S could afford Loan 2. I do not uphold the complaint about Loan 2. Loan 2 was repaid earlier than scheduled and that good repayment record is a relevant factor when Mrs S approached MoneyBoat again for Loan 3. Loan 3 Almost a month after repaying Loan 2 early, Mrs S applied to MoneyBoat for an £800 loan which was a little larger than Loan 2. Mrs S said to MoneyBoat that her income was £3,800 a month and that seemed to have been in line with the declared income for the previous month and so there was some consistency there. My observations surrounding income made earlier in this decision are repeated here. All the other elements on the application form are £0. But MoneyBoat increased her outgoings figure by £1,563 which was a very similar figure to the figure I came to on Loan 2 - around £1,547. Therefore, I do not consider that unreasonable to use it as a figure for all her outgoings. And I’ve reviewed the credit search report MoneyBoat did on 29 September 2025 and the figures were much the same as those reported in the credit search it had done in August 2025. Looking at the details, nothing had deteriorated, in fact the Budget account balance had reduced a lot, the delinquent account had a better reporting set of figures and its balance had reduced, and the defaulted account balances were being managed by Mrs S. She had an overdraft with a limit of £2,000 but it was recorded on the search MoneyBoat did as being at £0 at this point. And as I explained earlier, when a credit card is defaulted the limit level is usually reduced to £0 but as the balance stays the overall picture is of being ‘over the limit’ but that is a representation of the £0 limits for the defaulted accounts – not because of recent overspending on the ‘live’ cards.

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As I said at the beginning of this decision, I’ve looked at another complaint where a lender approved a loan for Mrs S in early September 2025. I have looked to see if that loan for £1,500 had registered with the CRAs by the time she was applying for the loan with MoneyBoat at the end of September 2025, and the answer is that it had not. And so MoneyBoat would not have known of that recent loan. I think that this gap in the MoneyBoat knowledge makes a difference. New credit accounts often take 8 weeks to register with CRAs and there is no expectation that MoneyBoat would have known of that 5 September 2025 loan with the other lender on 29 September 2025 when it did its check for this loan application. So, overall, I consider that MoneyBoat carried out proportionate checks and that although Mrs S did have some adverse data on her credit file, this was not enough at this stage for MoneyBoat to be promoted to carry out further checks. And as I have shown – if it had asked about her housing costs then the financial evidence Mrs S has sent to me has helped me to learn what her likely answer would have been. MoneyBoat is a lender used to lending to applicants with some adverse credit history. I do not uphold the complaint. I’ve also considered whether MoneyBoat acted unfairly or unreasonably in any other way and 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 it lent irresponsibly to Mrs S 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. My final decision My final decision is that I do not uphold the complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs S to accept or reject my decision before 21 May 2026. Rachael Williams Ombudsman

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