Savvy Loan Products Limited · DRN-6221430

The complaint Mr D complains that Savvy Loan Products Limited trading as Tick Tock Loans (“Savvy”) lent to him irresponsibly. What happened Mr D took two loans with Savvy: for £400 in April 2025 and for £300 in June 2025. The monthly instalment repayments over six months were scheduled as £127 and £93 (rounded) respectively. Loan 1 was repaid early on 2 May 2025 and then there was a gap before Mr D took Loan 2 – that was repaid early on 21 June 2025. After Mr D had complained and then had referred it to the Financial Ombudsman Service, one of our investigators did not think that Savvy had done anything wrong. Mr D disagreed and said: ‘Repayments were made through continued reliance on further borrowing, including other high-cost loans and revolving credit, rather than genuine disposable income.’ 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. 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: • I think the checks Savvy did before providing the credit were reasonable and proportionate given the loans it offered and what it knew about Mr D’s financial situation. It had verified his income as £3,000 and £3,100 a month after tax. This information was set out in the final response letter. Mr D has not challenged those. • Savvy has sent evidence listing the financial information Mr D had supplied with his applications and, using statistical data, has demonstrated how it increased the figures for his rent and general outgoings. My experience is that these are usually fairly accurate as they are based on address, post code, standard council tax banding and usual utility bills for a home of that kind. And so, I do not consider that unusual or unreasonable. And regulatory provision states that in most situations use of statistical data to augment an applicant’s own figures is appropriate and proportionate. • Savvy’s checks for Mr D’s credit history were detailed and up to date. I have reviewed them. At Loan 1, Mr D’s overall total debt was around £16,000, of which £12,708 was for a hire purchase agreement. As that’s for an asset and an item usually needed for business, commuting and/or daily lifestyle events, then this has a different complexion to other loan agreements. Mr D also had around seven smaller loans and around £2,300 on his credit cards. But he was only using around 59% of his total credit card limits and was managing his overdraft satisfactorily. Mr D’s open accounts had recent positive repayment records. • I calculated Mr D’s monthly credit commitment repayments as being around £1,140:

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Savvy had used a similar figure. At Loan 2 the credit situation looked much the same. • Mr D’s credit records showed he had experienced some financial difficulties in the past as he had seven defaulted accounts from December 2019 through to the most recent being in August 2021. But these were several years before he applied to Savvy. Mr D also had a judgment debt which Savvy had noted was satisfied – meaning paid off – but I have no details of that. Three of the defaulted accounts he was still paying off and two of those three were with debt collectors which likely indicated to Savvy safe management of those debts. And Savvy would not have been acting unreasonably to consider those default records as historic adverse data. It’s a lender used to extending credit to individuals with some poor credit history. • Based on the information Savvy gathered and what it knew about Mr D’s circumstances, there was nothing to suggest that Mr D was unable to sustainably repay what he was being lent. He had no issues with repaying his recent or existing credit. And although Mr D says that Savvy ought to have known more than it did, or ought to have found out more than Mr D had told it, this is not what the regulatory framework expects of a lender this early in a lending relationship where the two loans applied for were for £400 and £300 for short terms. • I appreciate that Mr D thinks the records Savvy gathered ought to have pointed to him being reliant on credit and therefore Savvy ought not to have lent to him. But for all the reasons I’ve given above I disagree. • I don’t think Savvy acted unfairly in any other way. This means I don’t think Savvy did anything wrong when it provided the loans to Mr D. I’ve also considered whether the relationship might have been unfair under s.140A of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Savvy lent irresponsibly to Mr D or otherwise treated him unfairly. I haven’t seen anything to suggest that s.140A or anything else would, given the facts of this complaint, lead to a different outcome here. I know this isn’t the outcome Mr D hoped for. But for the reasons above, I’m not asking Savvy to do anything to put things right. My final decision My final decision is that I’m not upholding Mr D’s complaint about Savvy. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr D to accept or reject my decision before 30 April 2026. Rachael Williams Ombudsman

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