Debt Management

A lender must not reactivate a credit account for a consumer known to have a gambling addiction and financial difficulties without conducting proper affordability assessments and considering vulnerability.

A lender must carry out a reasonable and proportionate affordability assessment that is borrower-focused, considering whether repayments would cause financial difficulty for the consumer.

A lender must carry out reasonable and proportionate affordability checks before providing credit, which may include reliance on credit reference agency data and statistical information rather than requiring full evidence of expenditure in

A creditor-debtor relationship is unfair under section 140A of the Consumer Credit Act 1974 only where the relationship is demonstrably unfair to the debtor, assessed by reference to the creditor's conduct, information provided, commission

A lender's initial lending decision is fair if based on reasonable and proportionate checks, and subsequent support obligations during persistent debt are met through appropriate notifications and suggested remedies.

A credit union must carry out reasonable affordability and creditworthiness checks before lending, but automated checks using income verification, credit reports, and ONS spending estimates are sufficient if they indicate sustainable repaym

A lender must conduct proportionate affordability checks appropriate to the credit amount and circumstances before providing credit.

A bank may refuse to issue a new card where it has reasonable grounds to believe the consumer may have difficulty repaying amounts owed, even if an advisor previously suggested otherwise.

A lender must carry out reasonable and proportionate affordability checks before providing credit, assessing both the likelihood of sustainable repayment and the impact on the borrower's circumstances.

A lender may register a default in accordance with ICO guidance when a consumer is at least three months behind with payments, provided it has offered appropriate forbearance and clear notice.

A default may be fairly reported when a consumer is 3+ months in arrears, or when an agreed arrangement is broken by non-payment.

Lenders must conduct proportionate affordability checks taking into account the loan amount, repayments, cost of credit, purpose, and consumer's circumstances, not a prescriptive set of checks.