Startline · DRN-6221982

The complaint when they provided her with a hire purchase agreement for the purchase of a motor vehicle. What happened Miss G applied for a hire purchase agreement with Startline to purchase a motor vehicle. Her application was approved, and the credit agreement was set in place in July 2022. In late 2025, Miss G complained. In summary, she said Startline had irresponsibly lent to her and that sufficient checks – to ensure her affordability status – hadn’t been undertaken. Startline didn’t uphold the complaint. They said, in summary, that they had carried out checks proportionate to the amount being lent; those checks hadn’t revealed any concerns, and on that basis, the credit had been provided. So, they were satisfied they had lent responsibly. Miss G disagreed; she still thought Startline were wrong to have lent to her, so she referred her complaint to this Service for independent review. An Investigator here considered what had happened; having done so, he didn’t think Startline had done anything wrong. In short, the Investigator said: • The checks carried out by Startline were proportionate in the circumstances. • The information gathered as a result of those checks wouldn’t have given Startline any cause for concern. And there was nothing that would have suggested to Startline that Miss G was struggling financially, and/or wouldn’t be able to afford the repayments towards the agreement. • Any financial struggles, which did materialise for Miss G later, wouldn’t have been apparent to Startline at the time they provided Miss G with the credit. • Overall, with that in mind, Startline hadn’t acted unfairly or unreasonably in providing Miss G with the finance. Miss G disagreed; she maintained she’d been irresponsibly lent to and said that Startline had failed to carry out proportionate checks. So, as no agreement has been reached by the parties, Miss G’s complaint has now been 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.

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Having done so, while this will no doubt disappoint Miss G, I agree with the findings of our Investigator and for broadly the same reasons. I’ll explain why. The rules and regulations in place at the time Miss G was provided with the credit, required Startline to carry out a reasonable and proportionate assessment. That’s to determine whether she could afford to repay what she owed in a sustainable manner. This practice is sometimes referred to as an ‘affordability assessment’ or ‘affordability check’. The checks had to be borrower focussed; that is, relevant to Miss G. So, Startline had to think about whether repaying the credit sustainably would cause her difficulties, or other adverse consequences. In other words, Startline had to consider the impact of any repayments on Miss G. Checks also had to be ‘proportionate’ to the specific circumstances of the lending. In general, what constitutes a proportionate affordability check will be dependent on a number of factors including – but not limited to – the particular circumstances of the consumer (e.g: their financial history, current situation and outlook, any indications of vulnerability or financial difficulty) and the amount/type/cost of credit they were seeking. I’ve kept all of this in mind when thinking about whether Startline did what they needed to before agreeing to lend to Miss G. Here, before agreeing to lend to Miss G, Startline checked data recorded with Credit Reference Agencies (“CRAs”); and it relied upon information provided by Miss G in her application. They also used information from the office of National Statistics (ONS data) to help estimate Miss G’s general living costs. I’ve been provided the results of Startline’s checks and, in my view, the data they gathered didn’t suggest that there was any real cause for concern. Rather, information obtained from CRAs didn’t show any recent defaults or County Court Judgments (“CCJs”), nor was Miss G subject to an Individual Voluntary Arrangement (“IVA”) at the time of the application – albeit I understand she entered into one later. Startline’s checks also showed that while Miss G held a high number of credit accounts, the combined balances of these accounts totalled a little under £6,000, with monthly payments totalling around £524 a month. And, while the credit check showed Miss G had one recent missed payment on one credit item a couple of months prior, this was brought up to date the following month, and the account balance at the time of Startline’s lending decision had been cleared to zero. Startline recorded Miss G’s income based on her own declaration at £27,000 a year, which equated to around £1,820 a month. They then verified this using a credit reference agency affordability tool that considers current account turnover (CATO) data, to help validate declared income. From the credit check they ran, they determined that Miss G’s monthly commitments towards existing credit equated to around £530 a month. And, when deducting this, along with the proposed repayment towards the hire purchase agreement of £311 a month, along with Miss G’s regular living costs – which they estimated using data obtained from the Office of National Statistics (ONS data); and adding a further £100 for discretionary spending – it showed Miss G to have around £343 remaining to cover any unexpected expenses. Having looked at the above figures, and the data Startline relied upon, it seems, that when deducting all of Miss G’s outstanding credit commitments, along with her living costs from the income they verified - and the contractual repayment due towards the hire purchase agreement she was taking out - Miss G would have still had adequate disposable income after these deductions to allow for any fluctuations in spending or emergencies if needed.

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So, on the face of things, I’m satisfied it was reasonable for Startline to conclude this lending was affordable for Miss G. Miss G has argued that her outgoings were actually higher than Startline concluded at the time of the lending, and that sight of her bank statements would have shown her financial circumstances to be much worse. I accept that what Miss G has said may indeed be the case, but it’s important to note that Startline are only expected to carry out ‘proportionate checks’, and in the circumstances, I’m satisfied that’s what they did. So, while I accept that a full financial review – which might have included reviewing evidence such as bank statements, and a full verification of incoming and outgoings for instance – may have uncovered that Miss G’s circumstances weren’t as positive as Startline had concluded. But in the circumstances, and given the level of borrowing in question, I don’t think it would have been proportionate to expect Startline’s checks to have gone that far, based on the initial evidence they had seen. So, based on the information Startline obtained, and given the amount, and purpose of the borrowing; as well as being satisfied that Startline carried out proportionate checks, I’m also satisfied that it was reasonable for them, based on the results of those checks, to conclude that the finance in question would have been affordable for Miss G. And I’ve seen nothing to suggest to Startline that Miss G wasn’t in a position to be able to repay it sustainably. So, while I am sorry to disappoint Miss G; I know this won’t be the outcome that she’s hoping for, it’s for the reasons I’ve explained that I don’t think Startline acted unfairly or unreasonably when they provided her with this agreement. Therefore, I won’t be asking them to do anything further in relation to their lending decision. Whilst I’m not upholding the complaint, I do want to remind Startline of their obligations to exercise forbearance moving forward. I would certainly encourage Miss G to keep in regular contact with Startline about any difficulties she’s now facing in maintaining any outstanding repayments that may be owed, or any other support she may require moving forward. I’ve also considered whether the relationship might have been unfair under Section 140A (S140A) of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Startline lent irresponsibly to Miss G or otherwise treated her unfairly in relation to this matter. I haven’t seen anything to suggest that S140A would, given the facts of this complaint, lead to a different outcome here. My final decision My final decision is that I do not uphold Miss G’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss G to accept or reject my decision before 21 April 2026. Brad McIlquham Ombudsman

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