Lendable Limited · DRN-6262221

The complaint Miss D complains that Lendable Limited, trading as Zable (Zable), irresponsibly lent to her, when it provided a credit card and subsequently increased the credit limit. What happened Miss D’s application for a credit card was accepted in August 2023, and Zable provided a £200 credit limit. In December 2023, Zable increased the credit limit to £500. Further limit increases were provided in June 2024 to £800, and January 2025 to £1,800. Miss D raised a complaint with Zable in August 2025. Miss D said the lending was provided to her without adequate consideration of affordability or her creditworthiness. Zable responded to Miss D’s complaint. It referenced the checks it had undertaken when issuing the credit card and as each credit limit increase was added. Zable was satisfied these checks provided a reasonable and proportionate assessment of Miss D’s creditworthiness and affordability. Zable also commented on a loan Miss D had taken with it and applied the same reasoning. Zable declined the complaints in respect of both the credit card and loan. In her submissions to this service, Miss D raised her concerns about the credit card account and the loan she had taken with Zable. Specifically, she stated her belief that Zable had lent to her irresponsibly, as she was in a spiral of debt. She was borrowing from lots of high-cost lenders to pay her living expenses and financial commitments. Miss D also stated she believed the credit checks undertaken by Zable were inadequate. And she believed the final credit limit increase was particularly irresponsible. An Investigator considered Miss D’s complaint in respect of the credit card lending. The Investigator concluded Zable had acted responsibly when providing the credit card and subsequent credit limit increases. This was because Miss D’s circumstances, and the Credit Reference Agency (CRA) data, indicated proportionate checks had been conducted. And there was nothing to indicate the decision to lend to Miss D was unfair. Zable didn’t dispute the Investigator’s view, but Miss D did. She highlighted that the amount of credit she had was significant. And she was living month to month on her overdraft and the small amount she was paying off her credit cards, which were maxed out. As an agreement could not be reached, the case was passed to me to decide. After carefully considering what both parties had to say on the matter, I explained that I was issuing a provisional decision as I was minded to reach a different conclusion to that of our investigator and partially uphold Miss D’s complaint. What I said in my provisional decision

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My consideration of this complaint relates to the credit card account, and the subsequent credit limit increases only. The sale of the loan is being considered separately. We’ve explained how we handle complaints about unaffordable and irresponsible lending on our website, and I’ve used this approach to help me decide Miss D’s complaint. The rules and regulations, in place at the time Zable provided Miss D with credit, required it to conduct a reasonable and proportionate assessment of whether she could afford to repay the borrowing in a sustainable manner. This is often referred to as an affordability assessment. The checks had to be focused on Miss D. This means Zable needed to conduct reasonable and proportionate checks to ensure it didn’t lend to Miss D irresponsibly. It had to consider the impact of the repayments on Miss D. There is no set list of checks it had to perform, but it could consider things such as the amount of the credit, the amount of the monthly repayments, and the overall circumstances of the borrower. Account opening I’ve considered whether Zable did what it should have when agreeing to provide a credit card to Miss D. The application process captured information relating to Miss D’s employment status and income. This was supplemented with information obtained from a CRA. Miss D said she was employed full time and had a net monthly income of £2,120. Zable advised this income figure was independently verified. Miss D also said her monthly rent payments were £415. The CRA data shows Miss D’s accounts were being maintained and her finances appeared stable. There was no evidence of arrears, County Court Judgements (CCJs), or an inability to meet her credit commitments. However, there were defaults on the credit record. Zable identified these and factored them into its lending decision. Zable conducted calculations to determine if the lending was affordable. It calculated that whilst maintaining recommended repayments for the card, Miss D would be spending 50.28% of her income in meeting her financial commitments and housing costs. This would leave a significant level of disposable income to meet other costs of living. This meant Miss D would also have available funds to meet any emergency or unexpected expenditure. In view of the opening limit of £200 provided, I’m satisfied the checks undertaken by Zable were reasonable and proportionate to the level of lending. Having concluded the checks were reasonable and proportionate, I’ve gone on to consider if the decision to provide the credit card was fair in respect of Miss D’s circumstances. I don’t agree with Miss D that Zable was remiss by not conducting additional credit checks. The evidence suggests Zable had a good understanding of her financial position. And there was nothing which should have prompted it to get a more in-depth view of Miss D’s circumstances. Zable considered her level of indebtedness, financial history, and financial obligations. When considered alongside her confirmed income, this suggests the potential borrowing was affordable. It follows therefore that I don’t believe Zable was unfair when it agreed to provide the credit card account. Credit limit increase one In December 2023, the credit limit on the account was increased from £200 to £500. Miss D’s indebtedness was recorded as between £11,301 and £11,400. And her verified income was £1,983. Monthly commitments to her credit arrangements totalled £694. This included

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what Zable said was a sustainable repayment to the Zable card. This suggests Miss D retained sufficient disposable income to meet other living costs and any unexpected financial expenditure. The CRA reporting didn’t show any adverse information at the time. I’ve noted that Miss D exceeded the credit limit on the Zable credit card, by a small amount, on a couple of occasions before the increase. I considered whether this should have prompted Zable to make additional enquiries before granting the limit increase. However, the overlimit amounts were typically driven by the addition of interest. And the card activity doesn’t indicate she was heavily reliant on credit, as most spending wasn’t for essential living costs. In light of the positive CRA data and the overall picture of Miss D’s finances at that point, which suggested she had capacity to meet her commitments, I’m satisfied the checks Zable conducted were reasonable and proportionate. Having concluded the checks were reasonable and proportionate, I’ve considered whether the decision to increase the credit limit was fair to Miss D. The increase to the credit limit was modest and the evidence suggests the potential additional borrowing was affordable. So, I’m persuaded that the decision to lend was fair. Credit limit increase two In June 2024, the credit limit on the account was raised from £500 to £800. Miss D’s indebtedness was recorded as between £11,001 and £11,100. And her verified income was £2,049. Monthly commitments to her credit arrangements totalled £861. This included what Zable said was a sustainable repayment to the Zable card. This again suggests Miss D retained a good level of disposable income to meet other living costs and contingency funds. In its response to Miss D, Zable said ‘your conduct meeting repayments and managing within limit has continued to evidence responsible use and affordability’. However, I’ve noted that since the previous limit increase, Miss D continued to exceed the credit limit on her account. This occurred on four occasions in the five months leading up to the credit limit increase. So, I considered whether this should have alerted Zable to make further enquiries, given that this now appeared to be a pattern of behaviour. Miss D, at the time, was making payments to the account in excess of the minimum required. But, looking at the account activity, she was frequently using the credit card for essential expenditure, for example, food. So, despite Miss D’s monthly payments, this spending resulted in the account quickly reaching, and then often exceeding, the credit limit. I believe Zable should therefore have been alerted to gain a greater understanding of Miss D’s finances before increasing the credit limit. It therefore follows I don’t believe the checks it conducted were reasonable and proportionate. I’ve considered Miss D’s bank statements in the three months leading up to the credit limit increase. To be clear, I’m not suggesting Zable should have reviewed the statements. There were a number of ways in which it could have gained a greater understanding of Miss D’s circumstances. But looking at the statements gives me a straightforward way to consider her financial position at the time. During the three months prior to the credit limit increase, Miss D was regularly using the overdraft on her current account. The overdraft usage was present for extended periods throughout each month, and the maximum usage was around £650. As a result of this, Miss D was incurring regular fees on her account. In addition, during the same period, Miss D obtained additional credit in each month from other lenders.

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Miss D’s average income over the period was around £2,321, and her committed expenditure averaged £2,156. This left an average of £165 to meet her other living expenses, including food, transport etc. So, I’m not satisfied this was sufficient to meet her expenditure, and to retain funds to address any unexpected or emergency financial impacts. When I consider Miss D’s circumstances at the time, it appears she was reliant on credit. I say this because, in the period before the increase her current account was regularly overdrawn. In addition, Miss D took out new credit arrangements, further increasing her indebtedness. And the Zable credit card showed signs of strain, as to some degree, Miss D was reliant upon it to meet essential expenditure and was then regularly exceeding her credit limit. These findings are consistent with what Miss D told us about her overdraft usage and reliance on credit to meet everyday expenditure. Taking all this into consideration, I believe at this point Miss D’s financial difficulties were evident. And if Zable had conducted further checks before granting the limit increase, it would have discovered that Miss D was likely unable to afford the additional credit. It follows therefore that I don’t believe the decision to increase the credit limit was fair to Miss D. As I’ve decided this increase was unfair, I’ve not considered the subsequent increases to the credit limit. Miss D has advised she has now begun to miss payments to her credit arrangements. I would encourage her to remain in contact with the lenders to ensure she gets the support she needs. In reaching my conclusions, I’ve also considered whether the lending relationship between Zable and Miss D might have been unfair to Miss D under Section 140A of the Consumer Credit Act 1974 (“CCA”). However, I’m satisfied that what I direct Zable to do in the section below results in fair compensation for Miss D given the overall circumstances of her complaint. For the reasons I’ve explained, I’m also satisfied that, based on what I’ve seen, no additional award is appropriate in this case. Responses to my provisional decision After considering what I had to say, Zable said it was the application of interest to Miss D’s account, rather than her spending, which resulted in the credit limit being exceeded. But nevertheless, Zable agreed with the provisional decision. Miss D said she agreed with the decision and had nothing further to add. 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. As I’ve not been presented with any new information or arguments that have made me change my mind, it therefore follows that I have reached the same conclusion for the same reasons that I set out above in my provisional decision.

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Putting things right As I have concluded Zable shouldn’t have increased Miss D’s credit limit above £500, I don’t think it’s fair for it to charge any interest or charges on any balances which exceeded that limit. Miss D has had the benefit of the money she spent on the account, so I think she should pay this back. Therefore, Zable should: Rework the account removing all interest, fees, charges, and insurances (not already refunded) that have been applied to balances above £500 after June 2024. If the rework results in a credit balance, this should be refunded to Miss D along with 8% simple interest per year* calculated from the date of each overpayment to the date of settlement. Zable should also remove all adverse information recorded after June 2024 regarding this account from Miss D’s credit file. Or, if after the rework the outstanding balance still exceeds £500, Zable should arrange an affordable repayment plan with Miss D for the remaining amount. Once Miss D has cleared the outstanding balance, any adverse information recorded after June 2024 in relation to the account should be removed from her credit file. If Zable has sold the debt to a third party, it should arrange to either buy back the debt from the third party or liaise with them to ensure the redress set out above is carried out promptly. *HM Revenue & Customs requires Zable to deduct tax from any award of interest. It must give Miss D a certificate showing how much tax has been taken off if she asks for one. My final decision It follows that I’m partially upholding this complaint as I don’t think Lendable Limited trading as Zable, lent to Miss D responsibly when increasing the credit limit on the account above £500. And I direct it to settle matters in the way I’ve outlined above. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss D to accept or reject my decision before 27 April 2026. David Hilton Ombudsman

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