National Westminster Bank Public Limited Company · DRN-6211352

The complaint Mr C complains that National Westminster Bank Public Limited Company provided him with an unaffordable credit card and didn’t act on signs of financial difficulty. What happened In December 2017 NatWest provided Mr C with a credit card with an original credit limit of £1,400. NatWest has confirmed no credit limit increases were provided. Mr C complained to NatWest in June 2025 about irresponsible and unaffordable lending. He said NatWest’s checks ought to have identified that the credit limit and ongoing provision of the credit card wasn’t responsible, as his financial circumstances didn’t support sustainable repayment of this lending. NatWest issued a final response in October 2025 in which it didn’t uphold Mr C’s complaint, saying it hadn’t acted unfairly by providing Mr C with this lending. Unhappy with NatWest’s response Mr C referred his complaint to our service for review. One of our investigators looked at the details of this complaint and considered it was reasonable to interpret it to be about the fairness of Mr C’s relationship with NatWest. As such they went on to review the details of the complaint on this basis. Having done so, they didn’t consider NatWest had acted unfairly in its lending decision, or in any other way during the provision of this credit agreement, so they didn’t uphold the complaint. NatWest accepted our investigator’s view; Mr C responded and disagreed. In summary, he maintained his position and said: • NatWest should reasonably have identified his credit card use wasn’t sustainable. • He managed the account close to or above the agreed limit; and only made payments at or close to the contractual monthly minimum. • NatWest had information available to it through its other lending relationships with him that showed signs of financial difficulty, and it should have acted across all accounts. • NatWest’s ongoing provision of the credit card on the same terms brought about an unfair relationship. Mr C has also drawn similarities between this complaint and two other complaints about other credit products NatWest provided, which have been considered by our service and have received uphold outcomes. Mr C asked for an ombudsman’s review, so 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.

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The information in this case is well known to Mr C and NatWest, so I don’t intend to repeat it in detail here. I’d like to assure both parties I’ve carefully reviewed everything available to me even though I may not have commented on it. I’ve purposely taken this approach because I’ve focused my decision on what I consider to be the key points of this complaint. I don’t mean to be discourteous to Mr C or NatWest by taking this approach, but this simply reflects the informal nature of our service. Initially I think it’s helpful for me to set out that there are time limits for bringing a complaint to our service, and NatWest has said Mr C’s complaint in part has been referred to us late. Our investigator set out within their view why they didn’t think we could look at a complaint about NatWest’s original lending decision, because it had been made more than six years after the event. But they also went on to explain why it was reasonable to interpret Mr C’s complaint as being about an unfair relationship as described in section 140A (s.140) of the Consumer Credit Act 1974 (CCA); and why they therefore considered Mr C’s complaint about an allegedly unfair lending relationship had been made to us in time. I don’t intend to go into the same level of detail in my decision here that our investigator already set out, but for the avoidance of doubt I agree with our investigator that I have the power to look at Mr C’s complaint on this basis. I say this because I’m satisfied Mr C’s complaint is in part that NatWest irresponsibly provided him with lending which was unaffordable. The provision of this credit card may have made the relationship between Mr C and NatWest unfair, as he may have paid more in interest and charges than he could afford. I acknowledge NatWest doesn’t agree we can look at any events more than six years before Mr C’s complaint was made, but as I’m not upholding this complaint I won’t be commenting on this further. In deciding what’s fair and reasonable I’m required to take into account, amongst other matters, relevant law. As I consider Mr C’s complaint is about the fairness of his relationship with NatWest, relevant law in this case includes s.140A-C of the CCA. S.140A says a court may make an order under s.140B if it determines that the relationship between the creditor (in this case NatWest) and the debtor (Mr C), arising out of a credit agreement is unfair to the debtor because of one or more of the following, having regard to all matters it thinks relevant: • any of the terms of the agreement. • the way in which the creditor has exercised or enforced any of his rights under the agreement. • any other thing done or not done by or on behalf of the creditor. Case law shows that a court assesses whether a relationship is unfair at the date of the hearing, or if the credit relationship ended before then, at the date it ended. That assessment has to be performed having regard to the whole history of the relationship. NatWest has confirmed the credit relationship ended in October 2025 when Mr C settled the account in full. So, Mr C has complained within six years of the relationship ending, and therefore I’m satisfied I can consider a complaint about an unfair relationship. S.140B sets out the types of orders a court can make where a credit relationship is found to be unfair – these are wide powers, including reducing the amount owed or requiring a refund, or to do or not do any particular thing. Given the details of Mr C’s complaint, I need to consider whether NatWest’s decision to lend to him, or any other actions it may have taken, created an unfairness in the relationship

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between him and NatWest; and if it did, whether NatWest took reasonable steps to remove that unfairness. We’ve set out our approach to complaints about irresponsible and unaffordable lending as well as the key rules, regulations and what we consider to be good industry practice on our website. I’ve followed this approach when considering Mr C’s complaint. Having done so, I don’t consider NatWest acted unfairly by providing this lending. I say this because: • While NatWest hasn’t provided our service with the data sitting behind the checks it says it completed before providing this original credit limit; like our investigator I’ve used the information provided on another of Mr C’s complaints about NatWest from around the time of this lending event, to understand what proportionate checks would more likely than not have shown it. • Based on reviewing this information, I’m satisfied Mr C had a reasonable level of disposable income to be able to afford the repayments to this credit limit. • I say this given the information shows Mr C’s income, non-discretionary expenditure and commitments to existing credit; and that this left a reasonable level of disposable income each month for Mr C to be able to afford at least the contractual monthly minimum repayments to this lending. Mr C has made reference to NatWest not acting fairly by continuing to provide him with this lending on the same terms across the years, given his financial circumstances. I’ve very carefully considered his comments, while taking into account the regulatory rules and requirements that were on NatWest throughout this lending relationship, and the outcomes our service has reached on his other lending complaints about NatWest. • As our investigator set out, the rules and requirements on lenders do vary across different types of lending products; however, I acknowledge an overarching principle and responsibility for a lender to act on signs of actual or potential financial difficulty. • Looking at Mr C’s management of his credit card, I’ve seen from January 2019 (the earliest statements available to me) to the account being closed, that Mr C’s balance largely remained close to the agreed limit. • However, while I acknowledge Mr C’s testimony that he only ever made minimum payments – or marginally above minimum payments – to his account, the fact that he was making at least the minimum payments (and I’ve seen largely regularly payments in excess of the minimum) I don’t consider ought reasonably to have caused NatWest concern; or reasonably have alerted it to potential or actual financial difficulties. • I acknowledge that as a monetary value the payments in excess of the contractual minimum are generally relatively modest; however, as a percentage they represent a greater value. And in any events payments in excess of the contractual minimum, aren’t the general repayment pattern of someone in potential or actual financial difficulties. • I note that Mr C had had periods of sustained months where his balance went above the agreed limit, and he incurred fees for this. However, I’ve seen that in these instances NatWest engaged with Mr C, making him aware of the status of the account; and I’ve seen that these letters included details of the support available to him if he was experiencing financial difficulty. These letters also set out the actions that could happen, including reporting adverse information to credit reference agencies. And NatWest sent Mr C persistent debt letters in line with its regulatory requirements. • Mr C largely brought the account back within the agreed limit within months of these events; so, I don’t consider it unreasonable that NatWest doesn’t appear to have

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taken further action after Mr C brought the agreement back in line with his contractual obligations. • I’ve also seen that NatWest declined multiple credit limit increase requests from Mr C across the years, suggesting it assessment of his affordability was conducted. • Once Mr C’s account had a sustained period of arrears in 2023, NatWest prevented further spending on the account to mitigate potential financial difficulties or further financial loss at that point. • The contact notes suggest Mr C failed to engage with NatWest following these communications; so, it was unable to obtain a thorough understanding of his financial circumstances. I don’t consider NatWest’s actions to prevent further spending on the account to have been unreasonable at this point, given the status of the credit agreement and Mr C’s apparent lack of engagement. • I note that Mr C did ultimately bring his account back in line with his contractual obligations, and made some sizeable payments to it which led to the balance being settled and the account being closed in October 2025. So, for the reasons I’ve set out above I’m not persuaded that NatWest acted unfairly when providing Mr C with this original credit card limit, or in the ongoing provision of the facility on the same terms. Where concerns with Mr C’s behaviours or management of the account were identified, NatWest engaged with Mr C and I consider took reasonable steps at each event; with the account ultimately being closed to further spending and being settled following full repayment of the outstanding balance. I acknowledge Mr C has drawn parallels to the other complaints he’s referred to our service about other NatWest lending; but when taking into account the individual details of this complaint, and the rules and regulations on NatWest, I don’t consider its actions to be unreasonable in relation to this credit agreement. I accept my decision will be disappointing to Mr C; I don’t doubt the testimony he’s provided about his personal and financial situation, and my decision here intended to downplay these circumstances. But for the reasons set out above I’m not directing NatWest to take any further action in resolution of this complaint. My final decision My final decision is that I don’t uphold Mr C’s complaint about National Westminster Bank Public Limited Company. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr C to accept or reject my decision before 28 April 2026. Richard Turner Ombudsman

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