Loans 2 Go Limited · DRN-6162065

The complaint Mr B complains Loans 2 Go Limited trading as Loans 2 Go lent to him irresponsibly when they provided him with a personal loan. What happened In December 2022, Mr B was provided with a personal loan by Loans 2 Go. The loan was for £2,000 and was repayable over 24 months with monthly repayments of £269 a month. In late 2025, Mr B complained. In summary, he said Loans 2 Go had irresponsibly lent to him and that sufficient checks – to ensure his affordability status – hadn’t been undertaken. Loans 2 Go didn’t uphold the complaint. They said, in summary, that they had carried out checks proportionate to the amount being lent; those checks hadn’t revealed any concerns, and on that basis, the credit had been provided. So, they were satisfied they had lent responsibly. Mr B disagreed; he still thought that Loans 2 Go were wrong to have lent to him. So, he referred his complaint to this Service for independent review. An Investigator here considered what had happened; having done so, she didn’t think Loans 2 Go had done anything wrong. In short, the Investigator said: • The checks carried out by Loans 2 Go were proportionate in the circumstances. • The information gathered as a result of those checks wouldn’t have given Loans 2 Go any cause for concern. And there was nothing that would have suggested to Loans 2 Go that Mr B was struggling financially and/or wouldn’t be able to afford the repayments towards the credit. • Any financial struggles, which did materialise for Mr B later, wouldn’t have been apparent to Loans 2 Go at the time they provided Mr B with the credit. • Overall, with that in mind, Loans 2 Go hadn’t acted unfairly or unreasonably in providing Mr B with this loan. Mr B disagreed; and maintained his argument that Loans 2 Go had failed to carry out proportionate checks and had lent to him irresponsibly. He said that his income was volatile; he ended up losing the money borrowed as a result of being victim to a scam; and he said, amongst other things, that this was the first loan he had ever taken out in his life, and he had no experience of borrowing on credit cards, and no understanding of how APR works. So, as no agreement has been reached, Mr B’s complaint has now been passed to me to decide.

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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, while this will no doubt disappoint Mr B, I agree with the findings of our Investigator, and for broadly the same reasons. I’ll explain why. The rules and regulations in place at the time Mr B was provided with the loan, required Loans 2 Go to carry out a reasonable and proportionate assessment. That’s to determine whether he could afford to repay what he owed in a sustainable manner. This practice is sometimes referred to as an ‘affordability assessment’ or ‘affordability check’. The checks had to be borrower focussed; that is, relevant to Mr B. So, Loans 2 Go had to think about whether repaying the credit sustainably would cause him difficulties, or other adverse consequences. In other words, Loans 2 Go had to consider the impact of any repayments on Mr B. 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 in mind when thinking about whether Loans 2 Go did what they needed to before agreeing to lend to Mr B. Here, before agreeing to lend, Loans 2 Go checked data recorded with Credit Reference Agencies (“CRAs”); and they relied upon information provided by Mr B in his application. I’ve been provided the results of Loans 2 Go’s checks and, in my view, the data they gathered didn’t suggest that there was any real cause for concern. Rather, information obtained from CRAs didn’t show any recent defaults or County Court Judgments (“CCJs”); nor was Mr B subject to an Individual Voluntary Arrangement (“IVA”). Loans 2 Go initially recorded Mr B’s monthly income at £2,427, based on what Mr B declared. In addition to this they noted from Mr B’s own declaration that he had housing costs of £595 a month, and his general living costs were around £500. But Loans 2 Go applied further scrutiny to their checks and revised down his income figure to £1,682 a month, having carried out income verification using a credit reference agency verification tool. They also used information from the office of National Statistics (ONS data) to help estimate Mr B’s general living costs, as well as carrying out a credit check to see what monthly commitments Mr B already had towards existing credit. Having done so, they estimated Mr B’s monthly expenditure to be in the region of £1,170, which seems reasonable based on the results of the checks, and was broadly in line with what Mr B disclosed. The results of the credit check showed no issues with payments, and the total balances of his existing credit was less than £1,000 with limited monthly repayments. So based on the above figures, it would appear that Mr B had in the region of £500 in disposable income each month, which he could use to make the monthly payments required towards the loan, as well as having money left over for any unexpected expenses. Keeping in mind the monthly repayments required to repay the loan, and, given that the CRA data hadn’t raised any immediate concerns; I think the checks undertaken by Loans 2 Go before lending to Mr B were proportionate, and the information they gathered suggested that

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a loan of £2,000 was likely to be affordable for him. So, I wouldn’t have expected Loans 2 Go’s checks to have gone further in the circumstances - given the level of borrowing in question; and I think it was reasonable for them to conclude this lending was affordable for Mr B at the time. Mr B has argued in response to the investigators view, that his income was volatile, and that this was the first loan he had ever taken out. However, I’ve set out above, how Loans 2 Go didn’t just take Mr B’s declared income at face value, but instead applied further scrutiny, and reduced the monthly income they used in their assessment. Turning to Mr B’s point that he had no prior experience of borrowing and that this was the first loan he had ever taken out in his life, I’m afraid I’m not persuaded his statement here is accurate. The credit check ran by Loans 2 Go show Mr B previously had one charge card, three credit card/store cards, three loans, as well as commitments towards communications companies, several of which had been repaid monthly for a significant amount of time. So, I’m not persuaded by Mr B’s statement here. I accept that Mr B feels Loans 2 Go’s checks should’ve gone further, but for the reasons already set out above, Loans 2 Go aren’t required to carry out an in-depth assessment of affordability at every lending assessment. Rather, their checks need to be proportionate to the circumstances of the lending. In this case, based on Mr B’s declarations; the amount of money he was borrowing; and the lack of any past repayment issues with previous credit commitments, I’m satisfied it was reasonable for Loans 2 Go to rely on the information Mr B provided when assessing affordability for the loan, along with the other checks they carried out to verify his income and outgoings, and not only do I think their assessment was reasonable, but they took extra precautions by decreasing their estimations of Mr B’s income; and, having done so, the results of the checks still showed the credit to be affordable for Mr B. So, while I appreciate this may disappoint Mr B, for the reasons set out above, I’m satisfied Loans 2 Go carried out proportionate checks, and that these checks showed the credit to be affordable. Subsequently I don’t think Loans 2 Go acted unfairly or unreasonably when they provided Mr B with this loan. So, it follows that I’m not upholding his complaint. Separately, whilst I’m not upholding the complaint, I do want to remind Loans 2 Go of their obligations to exercise forbearance moving forward. I would certainly encourage Mr B to keep in regular contact with Loans 2 Go about any difficulties he’s now facing in maintaining any outstanding repayments that may be owed. Finally, I’ve also considered whether the relationship might have been unfair under Section 140A (S140A) of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Loans 2 Go lent irresponsibly to Mr B or otherwise treated him unfairly in relation to this matter. I haven’t seen anything to suggest that S140A 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 Mr B’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr B to accept or reject my decision before 22 April 2026. Brad McIlquham

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Ombudsman

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