NATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY · DRN-6061937

The complaint Mr D complains that NATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY (NatWest) acted irresponsibly by providing him with a loan. What happened In February 2017, NatWest provided Mr D with a loan for £3,000. This was due to be repaid in 40 monthly instalments of around £101. The loan was repaid in full and settled in January 2020. In June 2025, Mr D complained to NatWest that giving him this loan was irresponsible considering they had also increased his overdraft limit shortly before. He also felt they should have been aware of his compulsive gambling issues. NatWest didn’t respond to Mr D’s complaint, so he referred it to the Financial Ombudsman. One of our investigators looked at the complaint and said it could reasonably be considered as being about an unfair credit relationship as described in Section 140A of the Consumer Credit Act 1974 (“Section 140A”). That being so, she felt it had been referred in time and went on to consider the merits of the complaint. Having done so however, she didn’t uphold it. Mr D didn’t agree with the opinion of the investigator and provided a detailed response. In summary, he didn’t agree that NatWest’s automated checks were adequate as his financial circumstances were worse than they’d found. Because an agreement couldn’t be reached, the complaint has 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. Having done so, I’m not upholding Mr D’s complaint. I know this is likely to be disappointing for Mr D, so I’ll explain the reasons for my decision. There are time limits for referring a complaint to the Financial Ombudsman Service, and NatWest think this complaint was referred to us too late. Our investigator explained why she didn’t, as a starting point, think we could look at a complaint about the lending decisions that happened more than six years before the complaint was made. But she also explained why it was reasonable to interpret the complaint as being about an unfair relationship as described in Section 140A and why this complaint about an allegedly unfair lending relationship had been referred to us in time. For the avoidance of doubt, I agree with our investigator that I have the power to look at the complaint on this basis. I think this complaint can reasonably be considered as being about an unfair relationship as Mr D says he made the majority of the loan repayments using his

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overdraft. This may have made the relationship unfair as he said it ultimately contributed to his debt spiralling. I acknowledge NatWest still don’t agree we can look at this complaint, but as I don’t think it should be upheld, I don’t intend to comment on this further. Given what Mr D has complained about, I need to consider whether NatWest’s decision to lend to him, or their later actions, created unfairness in the relationship between him and NatWest such that they ought to have acted to put right the unfairness – and if so whether they did enough to remove that unfairness. Mr D’s relationship with NatWest is therefore likely to be unfair if they didn’t carry out proportionate affordability checks and doing so would have revealed their lending to be irresponsible or unaffordable, and if they didn’t then remove the unfairness this created somehow. We’ve set out our general approach to complaints about unaffordable or irresponsible lending on our website, and I’ve taken this into account in deciding Mr D’s case. I’ve decided the credit was provided fairly because: • Before approving the application, NatWest asked Mr D for his income, his living costs and his housing costs. They also checked his credit file. • Mr D told NatWest his monthly income was £2,000 and his living costs were £556. He didn’t provide any housing costs, so NatWest relied on an application and affordability assessment from a few days prior when Mr D had confirmed housing costs of £500 – which I’m satisfied was reasonable in the circumstances. • The credit check showed Mr D had four open accounts and revolving limits of £6,500. There was no adverse information being reported at the time. • I can’t see that NatWest verified Mr D’s income but having looked at Mr D’s statements, I’m satisfied they would have been able to verify the income he declared in the loan application. • Based on the above figures, and after factoring the new loan repayment, Mr D was left with a disposable income of around £944 per month. I’m satisfied this was enough for Mr D to afford sustainable repayments towards his revolving debt even if he maxed out his available limits, as well as his discretionary spending. Based on what Mr D told NatWest and what they found for themselves, I’m satisfied the checks carried out were reasonable and proportionate to the loan applied for. There is no obligation either regulatory or good industry practice, that says NatWest needed to check Mr D’s bank statements. This means I don’t think NatWest did anything wrong when they provided the loan to Mr D. Mr D has provided us with a detailed response to our investigator’s view and mentioned his gambling addiction. And having reviewed his statements, I can indeed see these numerous gambling transactions in the lead up to the loan being credited to his account, and continuing afterwards. I thank Mr D for sharing this information and it’s clear he went through a very difficult time. However, I hope my decision goes some way to explain why I don’t think NatWest needed to go as far as reviewing his statements when deciding whether to lend to him or not. And so, I’m not persuaded they ought to have been aware of his gambling issues.

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In reaching my conclusions, I’ve also considered whether the lending relationship between NatWest and Mr D might have been unfair to Mr D under Section 140A. However, for the reasons I’ve already given, I don’t think NatWest lent irresponsibly to Mr D or otherwise treated him unfairly. I haven’t seen anything to suggest that Section 140A or anything else would, given the facts of this complaint, lead to a different outcome here. I appreciate Mr D feels very strongly about this matter and I know this isn’t the outcome he hoped for. But for the reasons above, I’m not asking NatWest to do anything to put things right. My final decision My final decision is that I’m not upholding Mr D’s complaint about NATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr D to accept or reject my decision before 21 April 2026. Amelie Makris Ombudsman

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