PROPEL HOLDINGS (UK) LIMITED · DRN-6252987

The complaint Mr R complains that PROPEL HOLDINGS (UK) LIMITED trading as Quid Market (Quid Market) gave him loans he couldn’t afford to repay without borrowing again. Mr R also says that he was stuck in a cycle of dependency. In addition, Mr R also says there has been a breach of CONC 3.7.5R by failing to disclose that taking these loans could lead to long term problems such as being declined for a mortgage. What happened Mr R’s borrowing can be found below. loan number loan amount agreement date repayment date number of instalments weekly or monthly contracted payment 1 £500 27/07/2023 17/11/2023 17 weekly £49.16 2 £1,000 17/11/2023 26/01/2024 13 weekly £116.18 3 £1,500 29/01/2024 13/02/2024 21 weekly £132.58 4 £1,500 27/05/2024 14/06/2024 21 weekly £126.04 break in lending 5 £1,500 02/05/2025 21/05/2025 5 monthly £534.96 6 £1,500 23/06/2025 31/07/2025 21 weekly £133.51 7 £1,000 26/08/2025 19/09/2025 21 weekly £83.99 Quid Market reviewed the complaint and made an offer to settle it in relation to loan 1 only. It agreement to refund the interest, fees and charges paid by Mr R, add 8% simple interest per year and then delete the loan from the credit file. All the other loans weren’t upheld. Mr R didn’t accept this offer. The complaint was reviewed by an Investigator, who only looked at loans 2 – 7 due to Quid Market already upholding loan 1. The Investigator didn’t uphold any of the other loans. Mr R didn’t agree with the outcome about loans 2 – 7 and I’ve summarised his responses below. • Loan 1 was upheld but then loan 2 was approved the same day the loan was repaid. • The Investigator has ignored CONC 5.2A.12R – that the loans weren’t sustainable. • Mr R took out new loans quickly after the previous loans were repaid. • Quid Market’s final response has an error when it set out the redress it was offering for loan 1. • Whether Quid Market used a buffer at loan 3 is irrelevant because Mr R was already servicing a lot of debt. • Mr R’s rent payments were £1,150 and a proportionate check would’ve showed that the Quid Market loan had funded this.

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• At loan 5 – Mr R took another loan on the same day from another high-cost lender for £2,000. • By the time of loan 6 – Mr R’s bank statements showed other payday lending and Quid Market’s failure to identify this is a breach of CONC 5.2A.24G. • When loans 6 and 7 were granted, Mr R was moving money between multiple lenders and was making payments to a number of other creditors. • Mr R’s bank statements also payments to a crypto exchange. • Quid Market failed to disclose – a breach of CONC 3.7.5.R2 – that the loans would impact his ability to obtain a mortgage and lead to further financial detriment. These comments didn’t change the Investigator’s mind and as no agreement could be reached 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. We’ve set out our general approach to complaints about short-term lending - including all the relevant rules, guidance and good industry practice - on our website. The lending decisions Quid Market had to assess the lending to check if Mr R could afford to pay back the amounts he’d borrowed without undue difficulty. It needed to do this in a way which was proportionate to the circumstances. Quid Market’s checks could have taken into account a number of different things, such as how much was being lent, the size of the repayments, and Mr R’s income and expenditure. This test that has been applied to Mr R’s complaint is in line with the regulations and guidance issued by the industry regulator in CONC 5.2A. With this in mind, I think in the early stages of a lending relationship, less thorough checks might have been proportionate. But certain factors might suggest Quid Market should have done more to establish that any lending was sustainable for Mr R. These factors include: • Mr R having a low income (reflecting that it could be more difficult to make any loan repayments to a given loan amount from a lower level of income); • The amounts to be repaid being especially high (reflecting that it could be more difficult to meet a higher repayment from a particular level of income); • Mr R having a large number of loans and/or having these loans over a long period of time (reflecting the risk that repeated refinancing may signal that the borrowing had become, or was becoming, unsustainable); • Mr R coming back for loans shortly after previous borrowing had been repaid (also suggestive of the borrowing becoming unsustainable). There may even come a point where the lending history and pattern of lending itself clearly demonstrates that the lending was unsustainable for Mr R. I have thought about this because there are times, when loans are taken close together, for example loan 2 was taken on the day loan 1 had been repaid. I can understand why Mr R may feel that there was a clear pattern of lending which he says leads the loans to be unsustainable. But when thinking about whether the pattern of lending itself would’ve indicated to Quid Market that the lending was harmful, I am mindful of the fact that there is a break of borrowing of just over 10 months between loan 4 being repaid and loan 5 be granted. This is important as it effectively reset the lending relationship.

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This meant that when Mr R returned for loan 5, Quid Market could treat him as if he were a new customer and so loan 5 in effect became loan 1 of a new lending chain and that did have an impact on what may be considered a proportionate check. As such, thinking about Mr R’s lending history, in my view, it hadn’t yet reached the point where Quid Market ought to have realised the lending was inherently harmful. Quid Market was required to establish whether Mr R could sustainably repay the loans – not just whether he technically had enough money to make his repayments. Having enough money to make the repayments could of course be an indicator that Mr R was able to repay his loans sustainably. But it doesn’t automatically follow that this is the case. Mr R in response to the Investigator’ assessment has outlined in some detail why he thinks each subsequent loan (from loan 1) ought to have been upheld and as part of this detailed response a number of footnotes were made with reference to a number of decisions he located on the decision database. I’ve noted these cases, but my role is to consider the individual circumstances of the complaint taking account of any relevant law and regulation. What that does mean is that there are times when what appear to be similar circumstances can lead to different outcomes depending on the type and nature of the borrowing and the types of check(s) any lender may have carried out and what those checks show. In short, other final decisions don’t set a precedent that I’m bound to follow. I’m satisfied in this case, I’ve fully considered the information Mr R gave to Quid Market as well as the checks it conducted, what those checks showed as well as accounting for the break in the borrowing relationship. Loan 1 Quid Market in the final response letter made an offer to resolve the complaint about this loan. The way it has calculated compensation which it has agreed to pay is in line with what the Financial Ombudsman Service would’ve recommend it pay to Mr R if the complaint about the loan had been upheld. I therefore see no reason to review this loan any further because Quid Market has accepted it shouldn’t have lent. But Quid Market should do what it has already agreed to do in order to put things right for Mr R – and I’ve set this out below. Loans 2- 4 I won’t go into as much detail for these loans because in the final response letter and the assessment by the Investigator set out the information provided by Mr R and what the checks showed Quid Market. So, Mr R’s income was cross checked using the same tool from the credit reference agency. And his income was between £5,000 and £6,000 per month after tax. Quid Market then took details of Mr R’s outgoings which were no more than £1,725 per month. It then went about checking this information – mainly using data from the credit reference agencies to cross check the information Mr R had provided about his credit commitments. Based on the income and expenditure checks – I consider these checks to be proportionate for these loans taking account of the income Mr R declared and which was cross checked

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and the information he provided about his outgoings which showed Quid Market the loans were affordable. Quid Market has provided the credit file data for each of these loans, and I’ve considered what it saw – again to see whether it ought to have done more before each application or whether it ought to have declined the applications. But there was no requirement for Quid Market to have carried out a credit search let alone one to a specific standard. It’s also the case, that recently opened accounts or accounts that had recent payment problems on may not have appeared within the data because those creditors wouldn’t have updated the record(s). But Quid Market was entitled to rely on the information provided to it by the credit reference unless it knew or ought to have known that it wasn’t accurate. Quid Market has provided the credit search data that it received, and I don’t think looking at them overall that Quid Market would’ve thought there was anything overly concerning. For loan 2, it knew in total Mr R had total debt of just over £3,000 and had four active accounts – one of which was the first loan granted by Quid Market. He had two credit cards – both within their limits and had been repaid as expected. There was also a current account. All the active accounts had been repaid as expected with no missed payment markets and I think it's fair to say that Quid Market was told that Mr R’s overall indebtedness was modest. There were also no defaults, CCJs or another type of insolvency. There wasn’t anything solely from the credit search results ought to have led Quid Market to have conducted further checks or to have declined Mr R’s application for credit. The credit check results for loans 3 and 4 were similar to what Quid Market received for loan 2. There were no defaults or adverse payment markers. Indeed, by May 2024, Mr R’s total debt was around £1,400. There was no reason, solely from the credit search to have prompted further checks. Quid Market was also entitled to have considered how Mr R had repaid its previous lending. And Mr R had also repaid his other loans as expected – indeed, he repaid all of them without any obvious problems and quicker than planned. There wasn’t anything in how Mr R had managed his Quid Market loans to have prompted it to undertake further checks. I’ve also considered that loan 2 and 3 were taken close to, or on the same day, a previous loan had been repaid – and I’ve thought about whether that ought to have led to further checks. But the quick up take, when it only happened twice isn’t enough for me to uphold these loans. Especially as these loans were repaid without difficulty, proportionate checks had been carried out which showed payments were affordable and the credit file data showed no signs of financial distress. It therefore follows that I don’t think Quid Market needed to have verified any of the information more closely than it did. As such, I wouldn’t have expected to have gathered bank statements for these loans. Overall, for these loans I’m satisfied the checks were proportionate which demonstrated Mr R would be able to afford these loans. As such I am not upholding his complaint about loans 2 – 4. Loans 5 – 7

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As I set out earlier in this decision due to the break in borrowing between loans 4 and 5 of almost a year, these loans in effect become a separate and new chain of lending. Loan 5 becomes loan 1 in a new chain of lending. For these loans Mr R told Quid Market that he received an income of at least £5,000 per month after tax. As before, Quid Market electronically cross-checked Mr R’s declared income. Again, for the first loans of a new chain, I consider it proportionate Quid Market relied on such a check. Mr R also provided details of his monthly outgoings including, his existing credit commitments. As before, Quid Market cross checked that information from the results of its credit search. After carrying out this cross check – for each loan Mr R demonstrated that he had a sufficient amount to afford his monthly or weekly payment due to Quid Market. I accept what Mr R says that his rent along was over £1,100 per month and on of course, top of that he would’ve had other costs such as utilities, insurance and council tax. However, that isn’t reflected in the information Mr R gave to Quid Market as part of his application for these loans. And, for the reasons given above, when thinking about the various factors that make up a proportionate check including income, outgoings and the repayments I don’t think Quid Market needed to look at his outgoings any more closely for the 3 loans in this chain. Quid Market also carried out a credit search and it has provided the results it received for each loan, and the same caveats apply to these results as they did for the loans in the previous lending chain. For loan 5 there had been a change in Mr R’s credit profile since the last lending chain. This time he had significant more debt at just over £62,000. The majority of this increase – around £42,000 of it was as a result of Mr R starting a hire purchase agreement for a vehicle in February 2025 – which was costing him £725 per month. I can see Quid Market included this payment in its affordability assessment. While Mr R’s debt had increased, he had received an asset for the payments – and so I do think Quid Market would’ve looked at this HP agreement differently to say lots of personal loans or credit card debt. Mr R also had more credit cards and more credit card debt – in total £12,654 and he also had a recently opened loan in November 2024 that was costing £307 per month. However, while Mr R clearly had more debt, all of the payments had been made as expected. And while Quid Market did know that Mr R was at times using an overdraft on one of his current accounts that alone isn’t enough to uphold the complaint – when considering the amount of overdraft being used compared to his income. As before, there were still no defaults, insolvencies or CCJs. Mr R for the purposes of the loan showed that he was managing his existing creditors. I’ve also fully reviewed the credit search results for both loans 6 and 7 and a similar picture was provided. There was more debt than in the previous lending chain, but it was being well managed and there again wasn’t any missed payments or adverse payment markers. As such, there was no need for Quid Market to verify or check this information more closely. The credit results showed similar information – that Mr R was on top of his existing creditors, there were no missed payments, defaults, CCJs or insolvencies. As such, given the rest of the checks that Quid Market carried then the decision to lend was fair because proportionate checks were made which showed these loans were affordable.

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I’ve thought about whether Quid Market ought to have gathered bank statements from Mr R. But given the information he had provided and the results of its own checks, I see no reason why bank statements would’ve been needed for this chain of lending because these loans appeared affordable. Having taken account of the three loans in this chain, what Quid Market discovered about Mr R from its credit checks as well as the information Mr R provided I’m satisfied Quid Market has fulfilled its obligations under CONC 5.2A to conduct a proportionate check before lending taking account of the sort of factors I set out at the start of the decision. I therefore do not uphold Mr R’s complaint about loans 5 – 7. Longer term problems in taking these loans Mr R has said that Quid Market failed to disclose that providing these loans could prevent him from obtaining a mortgage and so Mr R was deprived of making an informed decision. Mr R hasn’t provided any evidence to show that he has applied for a mortgage and has been declined solely due to the Quid Market loans being provided – and not for other reasons. I also can’t uphold the complaint about this element because Quid Market isn’t responsible for how other unconnected parties may view the entries it has made on Mr R’s credit file – bearing in mind it appears to have reported accurate information as to how Mr R repaid the loans – which is what it is expected to do. It’s of course possible, that the sight of Quid Market’s loans were seen negatively by a mortgage provider – but by Mr R’s own admission he has taken other expensive loans which may have had an equal or greater impact than the Quid Market loans. Finally, I’ve considered what Mr R has said about the failure to disclose under CONC 3.7.5.R2 (or CONC 3.7.4.A)– but this rule isn’t relevant to the complaint because this section of CONC is concerned with regulating credit brokers and the disclosure of commission and trading names. Which wasn’t how Quid Market wasn’t acting for this complaint. Indeed there doesn’t appear to a credit broker involved at all. As so, while I can see the section Mr R has quoted it doesn’t have any impact on this complaint. Putting things right Overall, I’ve also considered whether the relationship might have been unfair under Section 140A of the Consumer Credit Act 1974. However, I’m satisfied the redress set out below results in fair compensation for Mr R in the circumstances of his complaint. I’m satisfied, based on what I’ve seen, that no additional award would be appropriate in this case. In line with what Quid Market has already agreed to do, for loan 1 it should. A. Refund all interest, fees and charges paid by Mr R for this loan. B. To this sum, 8% simple interest should be added from the date of the payments to the date of settlement.* C. Pay Mr R the total of “A” plus “B”. D. Remove loan 1 from Mr R’s credit file. If Quid Market has already carried out the above compensation, it’s not required to do any more.

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*HM Revenue & Customs requires Quid Market to deduct tax from this interest. It should give Mr R a certificate showing how much tax it has deducted, if he asks for one. My final decision PROPEL HOLDINGS (UK) LIMITED trading as Quid Market has already made an offer to settle the complaint in the final response letter about loan 1 and I think this offer is fair in all the circumstances. So, my decision is that PROPEL HOLDINGS (UK) LIMITED trading as Quid Market should pay this offer. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr R to accept or reject my decision before 23 April 2026. Robert Walker Ombudsman

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