Lendable Ltd · DRN-6231561

The complaint Ms B complains Lendable Ltd trading as Zable (Zable) lent to her irresponsibly, approving her for a credit card that was unaffordable, due to the credit she already had. She also says Zable treated her unfairly when she informed them about her circumstances and that she was in financial difficulties. What happened In January 2023, Ms B took out a credit card with Zable. The card had a credit limit of £500. In December 2024, Ms B complained to Zable that they’d failed to carry out appropriate checks before the credit card was granted. At the time she also asked them to freeze interest and charges from being applied to her account and asked for contact to be by email, due to her suffering with her mental health. In February 2025, Zable sent Ms B their final response, but they didn’t uphold her complaint. In summary, Zable said they completed a comprehensive review of her financial situation before approving the credit card and from the information available, they found the servicing of the new credit card would be sustainable. Zable also said they’d offered Ms B a short-term payment plan on the account but because they’d not received an income and expenditure (I&E) form back from Ms B, they were unable to extend it. While Zable didn’t uphold Ms B’s complaint, they acknowledged they’d taken too long to respond, so they offered to credit £25 to her credit card account. Ms B went on to raise several complaints with Zable about the support offered to her, about how her financial distress and inability to afford the repayments to the card were being handled and about how she’d found the process of providing a breakdown of her I&E stressful. Zable upheld one complaint, crediting £50 to her credit card account in recognition of any distress and inconvenience caused by them failing to properly address her financial concerns and by their lack of clear communication. But they didn’t uphold the others. One of our Investigators looked into things and thought the checks Zable carried out prior to their lending decision were proportionate. And, based on the results of those checks, he thought Zable’s lending decision was fair. But while our Investigator didn’t uphold Ms B’s complaint about Zable’s lending decision, he upheld her concerns about their handling of her account, saying in part, he didn’t think £50 fairly recognised the financial detriment of their failure to apply the I&E Ms B had supplied to assist with her financial difficulties. Instead, our Investigator said Zable should pay £200 to Ms B directly and refund any interest and charges applied to her account between February 2025 when she’d sent the I&E in and May 2025, when a payment plan was then put in place. Zable responded to say the I&E form they received showed Ms B had a disposable income of around £277.57, so they were required to contact her to confirm if the figures were

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accurate. Then, while Ms B did return a further form, they were unable to link it to her account due to missing details. Our Investigator said while he accepted Zable’s comments, he still thought their offer of £50 was too low, and he remained of the opinion as the compensation was for distress and inconvenience and not a refund of interest or charges, Zable should pay it directly to Ms B. Zable accepted our Investigator’s view. But Ms B didn’t, letting him know she disagreed with both his opinion on Zable’s decision to lend to her and that she thought the compensation payment was too low. As Ms B remained unhappy, this case has been passed to me 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. Your Having done so, although I’m upholding this complaint, I appreciate it isn’t the outcome Ms B hoped for and I know it’ll come as a disappointment to her. I’ll explain my reasons for reaching my decision below. First, Ms B has explained in detail the impact Zable’s actions have had on her in respect of her mental health and financial hardship, and I want to thank her for that. I’m aware I’ve summarised this complaint in less detail in parts than has been provided, and I’ve done so using my own words. No discourtesy is intended by this. This reflects the nature of our service as an informal alternative to the courts. If there’s something I’ve not mentioned, it isn’t because I’ve ignored it. I haven’t. I’m satisfied I don’t need to repeat or comment on every detail here, to be able to reach what I think is the right outcome that’s reasonable in the circumstances of this complaint. Before I go on to explain my decision, I think it’s important to say a complaint brought to our service isn’t open ended and when a consumer is unhappy with a business’ actions, it’s important those concerns are raised with the business in the first instance before our service can look into things. Since our Investigator’s opinion on this complaint, Ms B has continued to remain dissatisfied with Zable’s handling of her credit card account. But this decision will focus on Zable’s actions up until point Ms B rejected our Investigator’s opinion only. It wouldn’t be fair for me to make a finding on what’s happened since, for the reason I’ve set out above. Should Ms B be dissatisfied with further actions taken by Zable, she should raise it with them directly and if she remains unhappy, she can refer those concerns to our service in their own right. Zable’s lending decision - How we handle complaints about irresponsible and unaffordable lending is explained on our website. It’s this approach I’ve used when deciding Ms B’s complaint. Zable needed to ensure that they didn’t lend irresponsibly, which in practice means they needed to carry out proportionate checks to be able to understand whether any lending was affordable for her

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before agreeing to provide the credit. The rules that apply to credit agreements are set out in the FCA’s consumer credit sourcebook (CONC). Section 5.2A of CONC is relevant here, as – among other things – it talks about the need for businesses like Zable to complete reasonable and proportionate creditworthiness assessments before agreeing to lend someone money. I’ve considered these rules by asking the following questions: • Did Zable complete reasonable and proportionate checks to satisfy themselves Ms B would be able to meet the repayments of the borrowing without experiencing significant adverse impact on her financial situation? - If they did, was their decision to lend to Ms B fair? • Did Zable act unfairly or unreasonably in any other way? Did Zable complete reasonable and proportionate affordability checks? What’s considered reasonable and proportionate in terms of the checks a business undertakes will vary depending on the details of the borrowing and the consumer’s specific circumstances at the time. While Ms B points to her account management after taking the card out, I must consider what Zable saw at the time of the application and decide if their lending decision was fair based on this, and not with information only available in hindsight. Here, Zable approved a credit card for Ms B with a limit of £500. This meant if she was to have utilised the full limit straightaway, she would’ve needed to have made monthly repayments of around £25 to have paid back the borrowing within a reasonable period of time. So, I think in the first instance Zable approved a credit limit for Ms B that was fairly modest both in respect of the amount of credit and the monthly repayments I think they ought to have factored in. So, my starting point is that I’d expect to see Zable to have gained an understanding of Ms B’s financial situation, proportionate to the credit in question. At the time of her application, Ms B declared she was employed full-time, earning a net monthly income of £1,420. Ms B also declared she’d one dependent who was reliant upon her financially, and that she was renting paying £460 a month. Zable verified the monthly income Ms B’s declared via an automated check with the credit reference agencies (CRAs). Automated income verification checks generally look at the amounts going through a customer’s current account. So, whilst they don’t provide quite the same level of certainty as bank statements or payslips, they do give a good level of confidence that someone’s income is what they’d said it was. So, while I understand Ms B raises that there was nothing stopping Zable from requesting evidence of her income directly from her, I don’t think they needed to have completed further checks here. I don’t think it would’ve been proportionate for them to have done so, given the amount of credit they were looking to approve. Zable also completed a credit check via the CRAs, to help them understand how Ms B

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managed both her current and existing finances. From the data provided, Zable saw Ms B had nine active credit agreements, consisting of five credit cards, two current accounts, a utilities account and a communications account. Ms B was utilising around 71% of her combined credit card limits at the time but all accounts appeared to be being well maintained, with only one sign of a missed payment in the last 12 months, however this appeared to be a one-off, with the account brought back into order the following month and the balance brought to zero three months later. Ms B had an overdraft limit on one of her current accounts which she was using at the time, and which Zable could see she’d used regularly over at least the 12 months prior. But, Zable could also see Ms B hadn’t exceeded her agreed limit and the account, along with the utilities account and communications account were being well maintained. Ms B’s total indebtedness at the time was around £11,100, with her commitments towards that debt totalling around £333 a month - equating to around 23% of her monthly income. Zable could see Ms B had taken out pay-day loans in the past but that the most recent of these was taken out and repaid in 2019. And Ms B could be seen not to have taken out any new credit agreements in at least the 12 months prior to the application. So in summary, the credit check showed Zable no signs Ms B had any other payments aside from the one I’ve mentioned, missed payments to any of her credit, that she’d not defaulted on any accounts, or that she’d been subject to any other adverse information which I think ought to have caused them concern about her ability to manage credit. I’m satisfied there wasn’t anything Zable saw in the credit file data they obtained to suggest Ms B was in financial difficulty or reliant on credit at the time of her application. Zable then completed an affordability check for which it took Ms B’s verified income and then considered Ms B’s declared rent and actual commitments to existing credit obtained from the CRAs, before factoring in the recommended amount Ms B would be advised to pay should she have utilised the full credit limit they were looking to agree straight away. While, as our Investigator explained, Zable haven’t specifically provided the figure they concluded Ms B would have for her non-discretionary expenditure, it’s clear from the calculations they have shared, it concluded she’d be left with £602 a month. So, when taking the above into account and when looking at all the data the credit check returned, I’ve seen no reason I think anything they saw ought to have prompted them to complete further checks. I wouldn’t expect Zable to have done more. Overall, I think Zable completed reasonable and proportionate checks and from all the evidence and information they gathered, I’m satisfied what they saw allowed them to fairly assess if the credit was affordable and sustainable for Ms B. But my above conclusion doesn’t automatically mean Zable went on to make a fair lending decision – it’s this I’ll go on to look at next. Did Zable make a fair lending decision? Zable verified Ms B’s monthly income as matching her declared amount of £1,420. In addition, when assessing Ms B’s affordability, Zable used a combination of her existing

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credit commitments alongside her declared housing cost, before factoring in the repayment that would be recommended towards the new agreement. After doing this, Zable found Ms B likely had around £602 a month for her remaining non-discretionary expenditure. I’ve already said I think the monthly repayment Zable needed to have factored in for the new agreement was around £25, the same as Zable used and around 4% of the figure they found Ms B would have for non-discretionary expenditure. So, I’m satisfied it was reasonable for them to have concluded the lending was affordable. I acknowledge Ms B says there was nothing stopping Zable from asking her about her expenditure directly. But having obtained her declared housing costs and actual commitments to existing credit, I don’t think it would’ve been proportionate. Ms B points to her bank statements as being further information of her actual expenditure at the time, but for me to review these, I’d need to be persuaded reasonable and proportionate checks would’ve involved Zable asking her about her other expenditure. And for the reasons I’ve explained, I don’t think that is the case. While I’m sorry it’s not the outcome Ms B hoped for, based on what I’ve seen, I’m satisfied Zable’s checks were reasonable and proportionate. I’m also satisfied they made a fair lending decision based on the outcome of those checks so I’m not upholding this element of her complaint. Did Zable act unfairly or unreasonably in some other way? I’ve considered whether Zable acted unfairly or unreasonably in some other way given what Ms B has complained about, including whether their relationship with Ms B might have been unfair under s.140A Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Zable lent irresponsibly to Ms B or otherwise treated her unfairly. I haven’t seen anything to suggest that Section 140A or anything else would, given the facts of this complaint, lead to a different outcome here. Zable’s handling of Ms B’s account – While it’s clear to me that Zable have taken steps to support Ms B, it’s equally clear they’ve fallen short on occasions, that their communication hasn’t been clear and they ought to have acted more promptly at times. A business can consider freezing interest and charges while a complaint is ongoing, but there is nothing to say they have to. But I would expect Zable to take Ms B’s circumstances into consideration when dealing with her, especially considering they were aware of both her mental health struggles and her financial difficulties. Zable placed a number of short-term holds and payment arrangements on Ms B’s account but then reverted back to their automated communication when those measures expired. I think they could’ve done more to manage the situation especially with their awareness of Ms B’s circumstances. From the evidence I’ve seen the initial I&E Ms B completed showed a positive monthly disposable income of around £277, so here I can understand why Zable wanted to confirm the figures. But then a further income and expenditure completed by Ms B couldn’t be located and here I think given Zable’s awareness of Ms B’s vulnerabilities, they could’ve done more to support

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her and be more pro-active in obtaining the information they required – instead of Ms B receiving prompts such as that her account would revert to requiring the contractual repayment that she’d been clear she couldn’t afford. So, I agree Zable ought to have done more to act promptly and support Ms B effectively with her financial concerns. And I also agree £50 isn’t enough to make up for not doing so. But having considered everything overall, I do think £200 in recognition of the distress and inconvenience Zable’s failings caused is fair and reasonable here. Because the compensation here is in recognition of distress and inconvenience caused, on this occasion I think it’s fair this amount is paid directly to Ms B, not offset against the debt she owes. I also agree Ms B shouldn’t be charged interest or charges on her account in between her payment arrangement ending in February 2025 and May 2025 when the next payment plan/hold was put in place. This reflects Ms B having already sent Zable the income and expenditure they’d told her was required to provide her more support. As it’s clear Zable are fully aware of Ms B’s mental health struggles and present financial difficulties, I’d remind them of their responsibility going forward to treat her with forbearance and due consideration. Putting things right To settle Ms B’s complaint Zable should do the following: • Pay Ms B directly, £200 compensation. Refund any interest or charges applied to Ms B’s credit card account between February 2025 and May 2025. My final decision My final decision is that I uphold Ms B’s complaint and instruct Lendable Ltd trading as Zable to settle the complaint as I’ve set out above. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms B to accept or reject my decision before 14 April 2026. Sean Pyke-Milne Ombudsman

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