PDL Finance Limited · DRN-6146424

The complaint Mrs N complains PDL Finance Limited trading as Mr Lender (“Mr Lender”) complains her loan was lent irresponsibly and should never have been given. What happened In March 2025 Mrs N applied for a loan with Mr Lender. The application was approved, and she was provided with £500. It was to be repaid over nine months with the highest repayment being £138.01. Mrs N complained in November 2025. She said the loan should never have been approved and appropriate checks weren’t carried out. Her circumstances at the time made it impossible for her to be able to sustainably repay the loan. She said she was always in her overdraft. Mr Lender responded to the complaint – they didn’t uphold it. They said based on the checks they completed at the time, the loan appeared affordable and Mrs N had sufficient disposable income to repay the loan. Mrs N didn’t agree, so she referred her complaint to our Service. An Investigator here looked into things. They agreed the checks were proportionate and Mr Lender made a fair decision to lend. Mr Lender responded accepting the finding, but Mrs N did not. She said she had other loans at the time of lending and she was continuously in her overdraft, and therefore her credit file couldn’t have been used. Because an agreement couldn’t be reached, the complaint 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. Having done so, I’m in agreement with the Investigator, that the checks were proportionate and a fair decision to lend was made. I know this is likely to disappoint Mrs N, but I’ll explain my reasoning below. The rules and regulations in place at the time Mr Lender provided Mrs N with the loan required them to carry out a reasonable and proportionate assessment of whether she could afford to repay what she owed in a sustainable manner. This is sometimes referred to as an ‘affordability assessment’ or ‘affordability check’. The checks had to be ‘borrower’ focused. This means Mr Lender had to think about whether repaying the credit sustainably would cause difficulties or adverse consequences for Mrs N. In other words, it wasn’t enough for Mr Lender to consider the likelihood of them getting the funds back or whether Mrs N’s circumstances met their lending criteria – they had to consider if Mrs N could sustainably repay the lending being provided to her. Checks also had to be ‘proportionate’ to the specific circumstances of the lending. In general, what constitutes a proportionate affordability check will be dependent on a number of factors including – but not limited to – the particular circumstances of the consumer (e.g. their financial history, current situation and outlook, any indications of vulnerability or financial difficulty) and the amount/type/cost of credit they were seeking. I’ve kept all of this

-- 1 of 2 --

in mind when thinking about whether Mr Lender did what was needed before lending to Mrs N. When Mrs N applied for the loan, Mr Lender gathered information regarding her financial circumstances. It recorded that she was earning a salary of around £2,600 per month and her outstanding debt cost around £400 a month. Mrs N didn’t appear to have adverse information on her credit file within the last two years and there was no payday lending. This, combined with the other expenses Mrs N declared left her with around £900 in disposable income a month. This was collated using the information Mrs N declared at application, and an external credit check. I believe the checks Mr Lender carried out were proportionate, and considering the amount being provided to Mrs N, and the information they gathered in these checks, I don’t think they acted unfairly when providing her with the loan. I say this because it was for a modest amount of £500, and there were no signs of financial difficulty in the past. It wouldn’t be a significant cost for Mrs N to repay this credit in a reasonable period of time based on her salary and existing credit commitments. I note what Mrs N has said regarding there being more loans on her credit file, but they weren’t visible to Mr Lender and I can only hold them accountable for what they saw at the time. I’ve also considered what Mrs N said about being in her overdraft continuously. I understand that this would’ve added pressure to Mrs N’s financial situation, but being in an overdraft alone isn’t an indicator of financial difficulty, and there wasn’t anything adverse being reported in her credit file. In reaching my conclusions, I’ve also considered whether the lending relationship between Mr Lender and Mrs N might have been unfair to Mrs N under s140A of the Consumer Credit Act 1974 (“CCA”). However, for the reasons I’ve already explained, I’m satisfied that Mr Lender did not lend irresponsibly when providing Mrs N with the loan. And I haven’t seen anything to suggest that s140A CCA would, given the facts of this complaint, lead to a different outcome here. So while it’ll likely come as a disappointment to Mrs N, I won’t be upholding her complaint against Mr Lender for the reasons explained above. My final decision It’s my final decision that I do not uphold the complaint against PDL Finance Limited trading as Mr Lender. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs N to accept or reject my decision before 27 April 2026. Meg Raymond Ombudsman

-- 2 of 2 --