Madison CF UK Limited · DRN-6268444

The complaint Mr S complains that Madison CF UK Limited trading as 118 118 Money irresponsibly lent to him. What happened Mr S complains about two loans 118 118 Money lent to him. 118 118 Money lent Mr S loan 1 in July 2020. This loan was for £1,000 with 24 monthly repayments of £80.39. In November 2021, 118 118 Money lent Mr S loan 2 for £1,505.58. Loan 2 had a term of 36 months with monthly instalments of £73.07. Loan 2 was used to settle the outstanding balance on loan 1. When Mr S complained to 118 118 Money, it didn’t uphold his complaint, so he referred his complaint to the Financial Ombudsman Service where it was looked at by one of our investigators. Our investigator concluded that 118 118 Money wasn’t wrong to lend either loan to Mr S. Mr S disagreed, he said he was vulnerable at the time due to his gambling addiction and ADHD. Mr S says 118 118 Money ought to have been aware the lending was irresponsible. As the complaint remains unresolved, it has been passed to me, an ombudsman to decide. 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. I’ve also taken into account the law, any relevant regulatory rules and good industry practice at the time the loans were offered. Before lending money to a consumer, a lender should take proportionate steps to understand whether the consumer could repay without borrowing further or suffering significant adverse consequences. A lender should gather enough information for it to be able to make an informed decision on the lending. Although the guidance and rules themselves didn’t set out compulsory checks, they did list a number of things a lender could consider before agreeing to lend. The key thing was that any checks needed to be proportionate and had to take into account a number of different things, including things such as how much was being lent and when what was being borrowed was due to be repaid. A lender should also react appropriately to what it knew about the consumer at the time it made its lending decision. 118 118 Money has provided information to show that before it lent either loan to Mr S, he completed an application, where he declared his monthly income and outgoings. 118 118 Money searched Mr S’ credit file. 118 118 Money says it verified Mr S’ income for loan 1 through credit reference agencies.

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Loan 1 Mr S declared an income of £1,800 for loan 1 but 118 118 Money says its checks showed that Mr S’ income was around £1,440, Mr S declared housing costs of £400 and other outgoings of £400. I can’t see that Mr S declared monthly credit commitment payments. 118 118 Money says it worked out Mr S’ credit commitments as £292.53 and his other living costs as £537.12.118 118 Money’s checks showed Mr S was left with around £120 disposable income after making repayments for this loan. Looking at the results of 118 118 Money’s checks, these showed that Mr S had two historic defaults from 2018. There were no County Court Judgements (CCJs) recorded on his credit file. I think it was reasonable for 118 118 Money to place less weight on the defaults as they were around two years before this loan was granted. Mr S has provided copies of his bank statements from around the time of the loan. I’ve used it to gain a better understanding of Mr S’ monthly income. From what I can see, Mr S’ bank statement shows his income was less than £1,800 which he declared and even with the lower income Mr S was left with sufficient disposable income after repaying this loan. So, had 118 118 Money taken its checks further to verify Mr S’ income beyond credit reference agencies, it’d have likely found he could afford the repayments. I’m also mindful this was Mr S’ first loan and his monthly repayment was less than 10% of his monthly income. Based on what 118 118 Money knew and ought to have known about Mr S at the time, I don’t think it was wrong to lend loan 1. Loan 2 By the time of loan 2, Mr S also had a credit card with 118 118 Money. So, 118 118 Money had more history about Mr S’ finances. 118 118 Money carried out similar checks to loan 1 and Mr S declared similar figures for his income and expenses for loans 1 and 2. The search into Mr S’ credit file found historic defaults like loan 1 and there was one satisfied default as well. There were no CCJs recorded. It is unclear whether 118 118 Money verified Mr S’ income as it did at the time of loan 1 but I think it ought to have done this. Mr S has provided copies of his bank statements, and I can see that his income had increased compared to the time of loan 1. Mr S’ three-month average income before this loan was around £2,654, higher than £1,800 which Mr S declared. Mr S’ bank statements don’t show significant living costs and 118 118 Money worked out his living costs to be around £500, housing costs to be around £400. The credit file showed Mr S’ monthly credit commitments were around £330. When Mr S’ outgoings is deducted from his income, he had sufficient income to repay the loan and have some left over. Based on what 118 118 Money knew or ought to have known about Mr S, I don’t think it was wrong to lend this loan. Mr S has said he was diagnosed with ADHD and had a gambling problem. I can see significant and frequent gambling transactions on Mr S’ bank statements. However, 118 118 Money isn’t required to request Mr S’ bank statements and I haven’t seen anything here that leads me to conclude it ought to have seen his bank statements before lending. It would have been reasonable for it to verify Mr S’ income through payslips for example. As it didn’t see Mr S’ bank statements, it was unaware about his gambling transactions and I’m mindful Mr S didn’t inform 118 118 Money about this. There also isn’t any information to show that 118 118 Money was aware of Mr S’ ADHD and how that impacted him.

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So while I understand Mr S’ concerns, these weren’t issues 118 118 Money knew about or ought to have known about from reasonable checks when it lent and so it couldn’t take them into account. Overall, I don’t think 118 118 Money acted unfairly towards Mr S when it lent loans 1 and 2. Has 118 118 Money acted unreasonably in some other way? I’ve also considered whether 118 118 Money acted unfairly or unreasonably in some other way, including whether its relationship with Mr S might have been viewed as unfair by a court under s.140A Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think 118 118 Money lent irresponsibly to Mr S 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 given above, I do not uphold Mr S’ complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr S to accept or reject my decision before 26 May 2026. Oyetola Oduola Ombudsman

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