Gain Credit LLC trading as Lending Stream · DRN-6122291

The complaint Mr G complains that Gain Credit LLC trading as Lending Stream lent to him multiple times irresponsibly. What happened Here is a table giving brief details of the lending. Loan Approved Amount Repayments (rounded) Repaid 1 19 February 2024 £150 £45 a month x 6 29 June 2024 2 13 April 2024 £400 £122 x 5 and £121 3 3 June 2024 £270 £21.50 /week 4 5 July 2024 £210 £64 a month x 6 5 September 2024 5 8 September 2024 £600 £208 a month x 5 and £162 15 December 2024 Seven month gap in lending 6 20 July 2025 £680 £224 x 5 and £223 7 2 September 2025 £610 £216 x 5 and £140 o/s in November 2025 After Mr G had complained and received the final response letter (FRL) in November 2025, Mr G owed money to Lending Stream on Loans 6 and 7. Mr G has explained that his credit commitment costs exceeded his income. He has told us that his credit was costing him £1,400 to £1,500 a month and he arranged to go into a Statutory Breathing Space on 21 October 2025. Lending Stream confirmed to us this was due to end 2 January 2026. Mr G has explained to us that the reason for him taking the credit was for gambling. And he says that Lending Stream ought to have known or found out about that. Lending Stream did not uphold his complaint and so Mr G referred it to the Financial Ombudsman Service. One of our investigators reviewed all that Lending Stream had done before lending and his view was that the complaint ought not be upheld. Mr G was dissatisfied and the unresolved complaint was 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. Lending Stream needed to make sure that it didn’t lend irresponsibly. In practice, what this means is that it needed to carry out proportionate checks to be able to understand whether any lending was sustainable for Mr G before providing it. Our website sets out what we typically think about when deciding whether a lender’s checks were proportionate. And I’ve used this approach to help me decide his complaint.

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Generally, we think it’s reasonable for a lender’s checks to be less thorough – in terms of how much information it gathers and what it does to verify that information – in the early stages of a lending relationship. But we might think it needed to do more if, for example, a borrower’s income was low, the amount lent was high, or the information the lender had – such as a significantly impaired credit history – suggested the lender needed to know more about a prospective borrower’s ability to repay. Loans 1 to 5 I’ve reviewed all the evidence supplied by Lending Stream as to the checks it carried out before lending on Loans 1 to 5. And I’ve read Mr G’s submissions. I asked to see the verification tool results Lending Stream used to check on Mr G’s income and having received that I am satisfied that it did verify his income and used the lower income figures to align with its more cautious approach. I consider that Lending Stream carried out proportionate checks and lent fairly for these five loans. The information I have shows that Mr G: - He had little outstanding debt overall and therefore his existing credit repayments were relatively low at Loans 1 to 5. The debt ranged from £1,806 to £2,675 overall. Mr G’s monthly credit commitment costs were £40 or £88 for the first three loans and then £480 and £561 a month for loans 4 and 5. So these were relatively modest and affordable; and - His income (verified using a credit reference agency system) was enough to cover those existing credit commitments, and the income amounts were between £1,590 and £1,600 a month after tax. - Lending Stream used information from Mr G about his general household and living expenditure but decided these were too low. It increased those figures using statistical data and having increased those to sums ranging from £455 to £599 a month then the loans looked affordable. - Lending Stream’s assessment of Mr G’s income and expenditure (including his credit commitment costs) led to it recognising that he had between £895 and £998 a month left over for loans 1 to 3. And for Loan 4 that figure was around £549 and for Loan 5 £201. The latter two figures were because Mr G’s use of credit had increased. But still his overall outstanding debt at Loans 4 and 5 was relatively modest at £1,806 and £2,675, respectively. - Mr G had no markers to show any defaulted accounts, no delinquencies, no insolvency markers and overall, the picture presented was of affordability. Lending Stream may take into account statistical data for working out Mr G’s ‘non- discretionary expenditure’, ‘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’. I am satisfied that Lending Stream would have had no cause to suspect his non- discretionary expenditure was ‘significantly higher’ in Mr G’s application circumstances. I consider that the checks it did were proportionate and fair lending decisions were made for Loans 1 to 5. I do not uphold the complaint about Loans 1 to 5. Loans 6 and 7 - gap There was a seven month gap between Mr G paying off Loan 5 and approaching Lending Stream again for Loan 6. And so, although Mr G has submitted that he considers that there was a ‘pattern of borrowing that should have prompted enhanced scrutiny’, I’m afraid that the opposite is the case. Here, with a seven month gap it’s not likely that Lending Stream would have considered that it needed to look further into his circumstances: it’s more likely it would

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have treated him like a new customer, or one that hadn’t needed to borrow for a reasonable time. Mr G has said that there was evidence of reliance on other lenders but even if Mr G had been using other lenders, that on its own is not a reason to refuse a loan application. Mr G has said that on several occasions when he logged into his Lending Stream account during this period between Loans 5 and 6, to check his eligibility for further borrowing ‘…the system indicated that Lending Stream was unable to offer me a loan at that time (or wording to that effect).’ We asked Lending Stream about this. It’s reply was: ‘The customer’s concern is that those loans should not have been approved, and as such, our response has focused on the checks and information we considered at the time of those decisions. In contrast, the reasons why other applications were declined do not inform or alter the assessment of the loans that were granted.’ I’ve received no evidence to fully demonstrate Mr G’s point from either party. My experience is that after Loan 5 many lenders do consider that individuals ought to ‘take a break’ and so that may have been the reason for Mr G seeing messages on his on-line account of not being considered ‘eligible’ – Mr G’s words not mine. Without clear evidence of what was happening during that period of time I can’t take this point further. And there’s no evidence of Mr G being declined by Lending Stream – rather that he was prevented from applying. That’s my interpretation of his submission and Lending Stream’s response on this point. Added to which, as and when Mr G applied for Loan 6 then the complaint is that Loan 6 was lent irresponsibly. I have looked to see what it was that Lending Stream would have seen as part of that application. Loan 6 At Loan 6 Mr G’s verified income was a little lower at £1,500, his overall outstanding debt had increased to £5,599 and Mr G was applying for a £1,000 loan which was higher than others before. The gap in the lending does lead me to conclude that it was fair and reasonable of Lending Stream to approach him as if he were a new customer. That means in practice that Lending Stream could use the information Mr G had provided to it when he applied for Loan 6 and was being reasonable to rely on it. However, still it carried out the checks it usually does. So, it verified Mr G’s income (£1,500 a month after tax), looked at the expenditure information Mr G had supplied to it and reviewed his credit commitment costs and his credit history. I asked to see the full raw data Lending Stream had relied on, I received that and I reviewed it all. On the credit history part, Mr G had no adverse history at all, his calculated credit costs were £574 a month. Mr G’s total expenditure figures were about the same as before at £530 a month. And so, the lower figure offered to him as a loan of £680 looked affordable. There was nothing there to suggest that Mr G was in financial trouble such that Lending Stream would have been expected to have conducted further checks. There were no insolvencies, late payments or adverse data to cause Lending Stream to be concerned. Mr G had one loan that looked to have been a payday loan as the one repayment was due to be for £301. But Lending Stream had factored this into its figures. The other unsecured loans were for longer periods and with smaller repayments each month.

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Mr G did use quite a lot of ‘deferred payment’ options in 2024 but that usually is a convenience multi-payment method offered at the point that items are purchased. And would not likely be viewed as being indicative of gambling or of overstretching Mr G’s finances. In any event, my analysis of the full credit search results showed that Mr G had only one of those sorts of accounts open when he applied to Lending Stream for Loan 6. And it was for £34 due to be paid off in two payments of £17 each. Mr G has said that he was heavily reliant on his bank overdrafts. Mr G’s current accounts had overdraft facilities and the credit search results show £0 as the outstanding balances on both. So, I do not accept that Lending Stream would have seen overuse of his overdraft. One credit card had a positive balance on it and the others were not at their maximum limits at all. One card had a promotional rate attached to it. Overall, I consider that Lending Stream carried out proportionate checks and would have had no need to have asked Mr G for additional information or do further checks. And so, it would not have seen any gambling transactions. And even if it had asked for copy statements I see that Mr G has sent to us copies from one bank but in his application forms gave the account details of another bank account. And so, it’s questionable as to which set he would have sent to Lending Stream even if asked. And in my experience, it’s not likely that Mr G would have sent to Lending Stream the copies showing multiple gambling transactions if that is what they show. I’ve no evidence that Mr G told Lending Stream of his gambling and again, it’s not likely he would have done. I do not uphold the complaint about Loan 6. Loan 7 Loan 7 was applied for when Mr G still owed Loan 6. But when Mr G applied for Loan 7, repayments on Loan 6 had been satisfactory. And so there would have been no need for Lending Stream to have been concerned due to that. The same or similar information about Mr G’s income and general expenditure was supplied by Mr G. Lending Stream has sent me details to show it had verified his income. I asked Lending Stream for the full credit search results it had carried out and I received them. They were in a different format, but I went through multiple coded lines of data to identify the salient details. Despite Mr G’s overall debt having increased to around £10,800 across 13 active accounts (of which three were identified as having a zero balance) his monthly cost each month to cover it had reduced to around £394 a month. Four accounts had been opened in the previous three months, one of which would have been Loan 6. Mr G had no mortgage. The total value of the loans and instalment credit accounts was £5,495, and the total value of revolving credit (accounts such as credit cards, store cards, mail order) was £4,576. The total limits on all revolving credit was £7,100 and his current balance used was 64% of that limit which was not excessive. Active loan accounts monthly repayments were £285 and the expected minimum repayment on all the revolving credit was about £138 a month. Which leads to the total monthly repayment figure to which Mr G was committed being about £423 a month. This is a similar total figure Lending Stream used in its affordability assessment of £394. The other adjustments Lending Stream made to Mr G’s declared figures for his monthly expenditure for things like rent and bills was small. And so, using Mr G’s income of £1,500 a month then he had around £489 left over with which to pay down the Loan 7 instalments. Mr G had asked for a £1,500 loan and Lending Stream having done the checks offered him a £610 loan which he took.

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I consider it carried out proportionate checks and lent fairly. I do not uphold the complaint about Loan 7. Breathing space Mr G has submitted that the proximity of him having to establish a Breathing Space after Loan 7 means that it should demonstrate Loans 6 and 7 ought never to have been approved. But I do not consider it fair or reasonable to look at events which happened after the lending decisions. I am being asked to assess whether Lending Stream lent responsibly at the time it made the decisions on Loans 6 and 7. My final decision My final decision is I do not uphold the complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr G to accept or reject my decision before 21 April 2026. Rachael Williams Ombudsman

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