FCA affordability requirements
Lenders are expected to consider creditworthiness and affordability risk before entering regulated credit agreements. Checks should be proportionate to the circumstances.
What is an unaffordable lending claim?
A claim may arise where a lender provided credit without making a proportionate assessment of whether you could sustainably afford repayments. The FCA describes high-cost credit as including products such as high-cost short-term credit, home-collected credit, rent-to-own, guarantor and logbook loans.
Responsible lending duties
A responsible lender should not ignore signs of repeat borrowing, existing debt, missed payments, vulnerability or reliance on further credit to make repayments.
Financial Ombudsman complaints
The Ombudsman considers complaints where consumers say credit was unaffordable or irresponsibly provided, and looks at what checks were carried out and what those checks showed.
How lenders get it wrong
Common failings include lending despite obvious pressure on household finances, encouraging repeat borrowing, or making checks that were too light for the level of risk.
- Repeat lending or refinancing that trapped customers in a cycle of debt.
- Rollovers or new loans used to repay old loans.
- Inadequate income, expenditure or credit checks.
- Lending despite arrears, missed payments or financial difficulty.
- Failure to identify vulnerability or persistent reliance on high-cost credit.
Why choose Ingram Toft?
Experienced claims specialists
Structured review of affordability indicators, lender behaviour and available evidence.
No Win No Fee
No upfront success fee. If compensation is recovered, our success fee is 25% plus VAT.
FCA authorised business
Clear disclosures, documented authority and secure handling of client information.
UK based team
Dedicated case managers support clients through the complaint process.
Multiple lender journey
Submit one claim journey covering every lender you remember, including unknown account numbers.
Secure digital process
Digital signature, address lookup, bank statement upload and CRM handoff for case handlers.
Previous industry refunds and complaint outcomes
High-cost credit complaints have resulted in refunds, balance adjustments and credit file corrections across the market. Some lenders have entered administration or redress processes, so outcomes depend on lender status and available routes.
Historic redress schemes
Where firms have failed or entered schemes, consumers may still have complaint routes, but recoveries can differ from active lender complaints.
Ombudsman decisions
Ombudsman outcomes often consider whether the lender’s checks were proportionate and whether lending was sustainable.
Credit file repair
Where lending should not have been provided, correction or removal of adverse information can be part of redress.
Sources: FCA high-cost credit and consumer credit; Financial Ombudsman unaffordable lending; FCA using claims management companies.
Customer success stories
Examples below are illustrative journeys showing the types of issues our specialists look for. Actual outcomes depend on lender records and evidence.
Repeat payday lending
A customer borrowed repeatedly over several months. The review focused on whether the pattern showed dependency and whether checks should have escalated.
Guarantor loan pressure
A borrower was approved despite existing debt and difficulty meeting household bills. The assessment considered affordability for both borrower and guarantor.
Doorstep credit cycle
Multiple loans were taken in succession. The claim summary highlighted repeat lending, repayment pressure and vulnerability indicators.
High-cost lending claim statistics
We only publish values we can support from current company data or fixed fee terms. Compensation recovered, average refund and success rate should be added once verified finance/reporting data is available.
2,800+high-cost lending enquiries in current CRM/nurture data
100+high-cost lending case files opened in current case data
25% + VATsuccess fee if compensation is recovered
£0upfront success fee on No Win No Fee claims
Search terms we help with
Unaffordable lending claims
Complaints about credit you could not sustainably afford.
Payday loan claims
Repeat payday lending, rollovers and short-term high-cost credit.
Responsible lending complaints
Claims about poor affordability or creditworthiness checks.
High cost credit complaints
Doorstep loans, guarantor loans, logbook loans and instalment loans.
FCA affordability complaints
Regulated credit complaints where lender checks may have been inadequate.
Financial Ombudsman lending complaints
Complaints that may need escalation if the lender rejects or fails to resolve them.