Barclays Bank UK PLC · DRN-6232221

The complaint Miss W complains that Barclays Bank UK PLC, trading as Barclaycard (‘Barclaycard’) irresponsibly gave her a credit card she couldn’t afford to repay. She also says they failed to properly help and support her when she was spending heavily on the card and using it for gambling and other transactions. What happened Miss W entered into an agreement with Barclaycard to have access to credit by way of a credit card account in March 2018, with an opening credit limit of £9,000. She used £4,600 of the credit to pay off some existing credit. Barclaycard didn’t uphold Miss W’s complaint. Our investigator thought the checks Barclaycard carried out before granting the card were reasonable and proportionate and that it went on to make a fair lending decision. However, having looked into the complaint further, he thought Barclaycard could have done more to support her given the level of transaction fees she was paying. So he recommended compensation for distress and inconvenience of £150. As Miss W is unhappy with this outcome, the complaint has been passed to me for a decision. 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. I’ve read and considered the whole file, but I’ll concentrate my comments on what I think is relevant. If I don’t comment on any specific point, it’s not because I’ve failed to take it on board and think about it, but because I don’t think I need to comment on it in order to reach what I think is the right outcome. 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 W’s complaint. I’m also very much aware that Miss W particular circumstances mean she has certain vulnerabilities as a consumer. Did Barclaycard make a fair lending decision? I’ve decided the credit card was provided fairly. I’ll explain why.

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I think the checks Barclaycard did before providing the credit were reasonable and proportionate, given the credit limit it offered and what it knew about Miss W’s financial situation. Barclaycard noted the income she’d put on her application and then looked at the amount she owed on credit elsewhere. There were no recent adverse markings on her credit file. Barclaycard then used the credit check to estimate her typical monthly expense to see if she had enough disposable income to be in a position to repay the new card. Based on the information Barclaycard gathered and what they knew about Miss W’s circumstances, I don’t think there was enough to suggest she was likely to be unable to sustainably repay the amount of credit she was being given. I therefore don’t think they acted unfairly. Did Barclaycard do enough to support Miss W with her card? Barclaycard needed to ensure that it provided Miss W with relevant support and that it had an awareness of the activity on her account. That said, gambling or other transactions such as trading are allowed and are not contrary to the Barclaycard’s terms and conditions. I also note that the gambling transactions showed on Miss W’s statements as PayPal transactions and as such wouldn’t have been readily identifiable due to their merchant coding. I therefore broadly agree with our investigator that the available credit card statements show a pattern of purchasing that doesn’t suggest she was likely to be getting into financial difficulty before March 2024. I’ve also seen the transactions that were made through trading sites in late 2021, early 2022 and again in late 2022. I would though expect Barclaycard to have some awareness of any use of the card that could suggest Miss W was at risk of getting into financial difficulty. Given that Miss W was repeatedly being charged for transaction fees that took place over a relatively short period, I agree that Barclaycard could have intervened to offer some support. This could have been done initially simply by writing to her with the suggestion that she make contact with them - but I can’t see that happened. Our investigator has suggested that Barclaycard makes a distress and inconvenience award of £150, in addition to the issues it has already compensated her for. I think that figure is fair and it’s in line with our approach. I note that Barclaycard has previously made two payments to Miss W relating to service issues and so those are for different matters. I’ve also thought about what more Barclaycard ought to have done in respect of Miss W’s vulnerabilities. I’ve seen customer notes showing she made them aware of this in or around March 2024. It was from then onwards that Barclaycard had an awareness of those vulnerabilities and was put in touch with their support team. This was with the aim of improving further interactions. I know Miss W says she’d already been in touch about this in 2020 – and I’m not suggesting that her recollection is wrong – but I can’t see evidence of that contact having been recorded. To summarise, I don’t think Barclaycard did anything wrong when it provided the credit card. But I do think it could have done more to support Miss W when she was using the card regularly for cash transactions, given the particular circumstances. I know Miss W was probably hoping for a different outcome on her complaint and I am sorry to have to disappoint her on this occasion. I’ve considered whether the relationship between Miss W and Barclaycard might have been unfair under Section140A of the Consumer Credit Act 1974. However, for the reasons I’ve

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already given, I don’t think Barclaycard lent irresponsibly to her 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. My final decision I require Barclays Bank UK PLC, trading as Barclaycard, to pay Miss W £150 compensation for distress and inconvenience. But I don’t think it needs to do anything more. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss W to accept or reject my decision before 23 April 2026. Michael Goldberg Ombudsman

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