PDL Finance Limited · DRN-6074481

The complaint Miss N complains that PDL Finance Limited trading as Mr Lender lent to her three times irresponsibly. For Loan 3 she has said she was in a debt management plan (DMP). What happened Miss N took three loans between March 2022 and May 2025 with large gaps in between paying one off and before applying for the next one. The first two loans were for £210 and £400, and the third loan was larger than the others at £1,000. At the end of February 2026, Loan 3 was outstanding still. The details of this complaint are well-known to both parties, so I won’t repeat them again here. The facts aren’t in dispute, so I’ll focus on giving the reasons for my 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. We’ve set out our general approach to complaints about unaffordable or irresponsible lending on our website and I’ve taken this into account in deciding Miss N’s case. I’ve decided the credit was provided fairly and I set out in the following paragraphs the reasons why I consider it to have been fair. I think the checks Mr Lender did before providing the credit were reasonable and proportionate given the amount lent at each application and what it knew about Miss N’s financial situation. Mr Lender’s checks showed that for Loan 1 she was living at home with her parents and so the lower sums for her household expenditure were understandably lower than say an individual paying a mortgage or renting privately. And the general household and living costs to which Miss N was committed (otherwise referred to as ‘non-discretionary expenditure’) was satisfactory. And for Loans 2 and 3 Miss N looked to have moved out as her rent and bills had increased. For each of the loans, Mr Lender carried out an income and expenditure analysis. As each loan was either when Miss N was a new applicant or after a significant gap since repaying the previous loan, Mr Lender was acting fairly and reasonably to treat each loan application as if Miss N was a new customer. That meant it was acting reasonably to rely on the information she had supplied to it. The disposable income (meaning the amount that was left over after she’d paid down all her committed costs) was between £792 and £934 a month. These loans looked affordable. For each loan Mr Lender did carry out a credit search. This was not a requirement within the regulatory framework and so there’s no particular standard or level of detail proscribed. What Mr Lender checked for seemed reasonable. I’ve received summaries of those credit search results and reviewed them. Miss N showed no signs through those credit searches of any insolvencies, judgement debts or bankruptcy within the previous three years. Plus, Miss N had no outstanding payday loans when applying for each loan. Other credit information was satisfactory.

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I’ve no information surrounding Miss N’s DMP, and there’s no evidence from either party to demonstrate that either Miss N told Mr Lender or that Mr Lender was aware of that DMP. In any event, being in a DMP, by itself, would not automatically lead me to think that Mr Lender was required to refuse any loan applications from Miss N. Miss N has raised a point surrounding Mr Lender’s use of Office of National Statistics (ONS) data. I think our investigator referred to this. But I’ve looked at all that Mr Lender has sent and there’s no reference to it having used ONS data. Even if it had, the Consumer Credit Sourcebook which gives rules and guidance to lenders on responsible lending does provide that a lender ‘… may take into account statistical data unless it knows or has reasonable cause to suspect that the customer’s non-discretionary expenditure is significantly higher than that described in the data or that the data are unlikely to be reasonably representative of the customer’s situation.’ So, Miss N’s situation seems to fall into that category at each loan application where if Mr Lender had used ONS data that would have been fair and reasonable. Based on the information Mr Lender gathered and what it knew about Miss N’s circumstances, there was nothing to suggest Miss N was likely unable to sustainably repay what she was being lent. Loans 1 and 2 were for modest sums. Miss N considers that Loan 3 was large but overall, it was not a large amount. Miss N had no issues with repayment of her recent or existing credit from the Mr Lender searches about which I know. And although Miss N says that Mr Lender ought to have known more than it did, or ought to have found out more than Miss N had told it, this is not what the regulatory framework expects of a lender. I don’t think Mr Lender acted unfairly in any other way. This all means I don’t think Mr Lender did anything wrong when it provided the loans to Miss N. I’ve also considered whether the relationship might have been unfair under s.140A of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Mr Lender lent irresponsibly to Miss N or otherwise treated her unfairly. I haven’t seen anything to suggest that s.140A or anything else would, given the facts of this complaint, lead to a different outcome here. I know this isn’t the outcome Miss N hoped for. But for the reasons above, I’m not asking Mr Lender to do anything to put things right. My final decision My final decision is that I’m not upholding Miss N’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss N to accept or reject my decision before 14 April 2026. Rachael Williams Ombudsman

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