Vanquis Bank Limited · DRN-6031934

The complaint Mr F complains that Vanquis Bank Limited (Vanquis Bank) acted irresponsibly when they agreed to lend to him. What happened In June 2025 Mr F successfully applied for a credit card with Vanquis Bank with a credit limit of £3,000. He complains that he was already in a cycle of borrowing at the time, and so the lending was unaffordable. He does not think the checks carried out by Vanquis Bank were sufficient, and had they done sufficient checks they would have found he had a high level of debt, significant gambling transactions and had been discharged from an Individual Voluntary Arrangement (IVA) in 2022. Vanquis Bank say that they considered Mr F’s overall creditworthiness and based on this they felt that they’d made a fair lending decision. Mr F says he didn’t think Vanquis Bank addressed his complaint properly and he wasn’t able to attach evidence to his complaint with them. As Mr F wasn’t happy with Vanquis Bank’s response, he referred his complaint to us. In summary, our investigator said that they thought the checks which Vanquis Bank carried out were reasonable and proportionate in the circumstances, and that based on the information from these checks, the decision to lend was fair. Vanquis Bank didn’t dispute this position, but Mr F did. In summary he said that in the two years leading up to this application, he had opened around ten new credit accounts, including credit cards and other forms of borrowing. He also had lending with other providers which wouldn’t have shown on all credit agency checks, so thinks Vanquis Bank didn’t have an accurate picture of his full financial commitments. He said another credit provider found that lending to him was unsuitable and so thinks this outcome is inconsistent. His continued lending has led to him being on a debt management plan. Our investigator explained that each complaint must be considered on its own merits, and in this case they found the checks were reasonable and proportionate and it was fair for Vanquis Bank to rely on the information from those checks. They didn’t think the credit file information leading up to the lending indicated financial difficulties. Further, Mr F took advantage of a 0% interest balance transfer incentive. Ultimately a resolution wasn’t made, and so the 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. While Mr F has provided detailed evidence of his complaint, and whilst I’ve considered all the available information, I’ve not reflected every point that has been raised. No discourtesy is intended here, this is merely to reflect my informal role in deciding a fair and reasonable

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outcome. So, I’ve focused on what I think are the key issues of the complaint. If there is something I haven’t mentioned, it isn’t because I’ve ignored it. I’ve considered what both parties have said about Mr F’s lending with Vanquis Bank. Having carefully considered everything, I think that Vanquis Bank acted fairly and reasonably. The relevant rules, regulations, and guidance at the time of Vanquis Bank’s lending decision required them to carry out proportionate checks. While there isn’t a defined list of checks a lender needs to carry out, such checks should be proportionate, considering things like the type, amount, duration and total cost of the credit, as well as the borrower’s individual circumstances. These checks needed to assess Mr F’s ability to afford the loan being approved and to be able to repay it sustainably, without causing him financial difficulties or harm. It isn’t sufficient for Vanquis Bank to just complete proportionate checks, they must also consider the information obtained from these checks to make fair lending decisions. I’ve considered the checks Vanquis Bank did and what they found from these checks. Vanquis Bank reviewed the declared salary and disposable income information provided by Mr F in his application and completed a credit check to understand his credit commitments. Mr F declared he was in full time employment with an annual income of £38,700, which was validated by Vanquis Bank to find a net monthly income of £2,615. Mr F said he had housing costs of £900 per month and had one dependant. Vanquis Bank calculated he had monthly living costs of around £554 and Credit Reference Agency (CRA) data found that Mr F had existing credit commitments of around £489. Taking this and other required income into consideration, Vanquis Bank found that Mr F had a disposable income of £482. Vanquis Bank also checked Mr F’s credit file which showed he had an outstanding debt of £16,900, which was being well managed. There were no recent defaults, and all accounts were up to date. There were no County Court Judgments (CCJs), IVAs or bankruptcies recorded. Mr F has said that one of his recently acquired credit cards was highly utilised by the time of this application, but at the point these checks were made, this was not yet evident. Similarly, although he was discharged from an IVA in 2022, by the time of this check, this was not shown. Mr F thought that the CRA data reviewed wasn’t sufficient to give a full picture of his financial situation, as some credit wouldn’t have shown there. However, I think that it was reasonable for Vanquis Bank to take into account the CRA data they did. I don’t think there was anything from the information available which ought to have prompted Vanquis Bank to take steps to review other CRA sources. This credit card also offered a balance transfer incentive, which gave an interest rate of 0% for 15 months, meaning Mr F also had an opportunity to reduce some of his existing credit repayments over this offer period. Taking this, the amount of disposable income, the information available on Mr F’s credit file at the time, and level of lending into account, I’m satisfied that the checks done were sufficient, being reasonable and proportionate in the circumstances. I also have to consider if, based on the information within these checks, the information was considered fairly. At the time the account was opened, Mr F was found to have around £482 in disposable income. I think that this was sufficient to show that the lending was affordable and payments could be made sustainably. As well as this, Mr F was offered and took advantage of a 0% balance transfer offer which could be expected to have put him in a better position for some

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of his existing credit during the terms of the offer. At the time of the complaint, no interest had been added to the account. Mr F says that by May 2025, his unsecured debt had reached around £17,300 but not all of this would have shown on his credit file. He says he was discharged from an IVA in 2022 and that he was particularly vulnerable as a single parent. He also said that had further checks been done, they would have revealed significant gambling transactions. However, I don’t think this information was evident from the reasonable and proportionate checks that were carried out. As such, I don’t think it would be fair to expect Vanquis Bank to have taken this additional information into account. There wasn’t anything from the credit file checks that I think suggested Mr F was in financial difficulty at the time or that the lending would not be sustainable without causing financial harm. Taking all of this into account, I think that the decision to lend was fair. Mr F says that other credit providers upheld his complaints with them and so thinks this complaint should also be upheld. Complaints must be considered on their own merits, and I think that in this case the checks that were carried out were reasonable and proportionate and the resulting decision to lend was fair. Mr F also raised concerns that Vanquis Bank’s response to his complaint didn’t properly address his concerns, and he wasn’t able to attach evidence for them to review. Mr F has now been able to provide this evidence as part of his complaint to this service and evidence from both sides has been considered. I’m satisfied that Vanquis Bank don’t need to take any further action here. Mr F has said that he thinks the interest rate will be unaffordable once the 0% interest offer ends, however this has not yet occurred and no interest has been applied. I don’t think there was anything prior to the complaint being raised that means Vanquis Bank ought to have taken further actions here. But I would also expect Vanquis Bank to show forbearance if Mr F gets in touch with them regarding any difficulties with the repayments towards the account, such as a temporary payment arrangement if suitable. In reaching my conclusion, I’ve also considered whether the lending relationship between Mr F and Vanquis Bank might have been unfair to Mr F under Section 140A of the Consumer Credit Act 1974 (“CCA”). However, for the reasons I’ve already explained, I’m satisfied that Vanquis Bank did not lend irresponsibly when providing Mr F with the credit account or otherwise treat him unfairly in relation to this matter. And I haven’t seen anything to suggest that Section 140A CCA 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 this complaint against Vanquis Bank Limited. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr F to accept or reject my decision before 16 April 2026. Frances Kerslake Ombudsman

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