Steadypay Limited · DRN-6153263

The complaint Mr C complains that Steadypay Limited (“Steadypay”) gave him a running credit facility which he couldn’t afford to repay. Mr C had financial difficulties, and he is unhappy with the help and support provided by Steadypay. Mr C has also said that there have been problems with Steadypay collecting his payments due to a problem with its app. However, Steadypay says the issue was with Mr C’s bank. What happened In September 2024, Mr C was given a running credit account with a limit of £300 and he drew down on the facility one time. Mr C had some difficulties repaying the debt and following an agreement with Steadypay, the balance was repaid and the account closed in February 2025. Steadypay considered Mr C’s complaint points and didn’t uphold it. Mr C then referred the complaint to the Financial Ombudsman. Later Steadypay, as a gesture of goodwill, offered to remove the negative information from Mr C’s credit file. However, he didn’t accept this offer and Steadypay has confirmed this offer is now no longer available to Mr C. An Investigator considered the complaint and after a number of views, didn’t uphold it. The Investigator was satisfied that the credit agreement correctly set out how the account would work and how the membership fee was applied and that Steadypay had fairly provided the facility. The Investigator also concluded that Steadypay had attempted to collect the required payments, but these were declined by Mr C’s bank. Mr C didn’t agree with the outcome, and I’ve summarised his responses below; • Mr C says he also filed a formal complaint through the chat on the website but this was ignored and his payments would be postponed for 30 days – this wasn’t done. • Mr C had tried to make payment with his new card but due to an error with the app – these payments weren’t successful. The payments only started being made once he paid an invoice he received in December 2024. • Steadypay was confused about which debit card Mr C was talking about. Mr C accepted his ‘old’ debit card had been declined (the one connected to his current account) whereas Steadypay said his new card was declined. • Mr C says he didn’t give Steadypay the authority to add the new card to the account and to be used for a continuous payment authority (CPA). He was merely using the card to make a one-off payment. This is shown because Mr C was asking for new invoices in order to make the payments that were due under the repayment plan. • Mr C says payments declined but this was during the time that Steadypay was working with his debt management company. • Mr C says the credit check results would’ve shown he was using 70% of his available credit and he had previously been denied loans which had smaller monthly repayments. • Steadypay has blocked him access to the online account.

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• Dealing with this has caused a lot of stress. Later, a further view was issued where the Investigator said that no error had been made when the new card was added to the account and was then used as part of the CPA – this was and is outlined in the account terms and conditions. Mr C didn’t agree and provided a summary document of what he’s unhappy about. All of which I have read. These points didn’t change the Investigator’s mind and so 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. I’ve read everything that the parties have said, but I’ll concentrate my comments on what I think is relevant. If I don’t comment on a specific point, it’s not because I’ve failed to consider it, but because I don’t think I need to comment in order to reach a fair and reasonable outcome. And our rules allow me to do this. This reflects the nature of our service as a free and informal alternative to the courts. Firstly, I’m sorry to hear about the health problems Mr C experienced which he says partly contributed to taking out the facility with Steadypay. It couldn’t have been easy to let us know and I do hope that things have improved for Mr C. For ease of reading, I’ve split the decision into various subsections. Lending decision We’ve explained how we handle complaints about unaffordable and irresponsible lending on our website. I have used this approach to help me decide Mr C’s complaint. Steadypay needed to make sure it lent responsibly to Mr C. It therefore needed to complete sufficient checks to determine if Mr C could afford to sustainably repay the lending. Our website sets out our approach to what we typically think when deciding if a lender’s checks were proportionate. There is no set list of checks a lender should do, but there is guidance on the types of checks a lender could complete. However, these checks needed to be proportionate when considering things like the amount and term of the lending, what the lender already knew about the consumer, etc. It’s useful to set out how this product worked. The facility – called Cash Wave worked by giving Mr C a credit limit – in this case £300. He could withdraw on the facility, but the balance had to be repaid within 120 days – and a representative example is provided in the credit agreement. Had Mr C borrowed £300 – repaid it over 120 days he would repay a total of £390 or £130 per month. Which was the £300 capital borrowed and three months’ worth of monthly membership fees. It is important to note that no interest was charged on this facility interest instead a monthly membership fee of £30 per month was paid – but the membership fee is only charged if the facility is being used. All of this information is set out in the credit agreement. Turning to the checks completed, Steadypay has said before agreed to advance the facility it performed an income and expenditure check – which was cross checked through an opening banking (OB) report. Steadypay also carried out a credit search. Having carried out

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these checks, Steadypay was content to open the facility. Having looked at everything, I’m satisfied the checks were proportionate. Mr C’s income was checked and Steadypay was aware in the months before the facility was approved. I think it’s fair to say that Steadypay had an accurate idea of what Mr C earned. A credit search was also carried out and Steadypay have provided the results it received from the credit reference agency. It’s worth adding here that isn’t a requirement to carry out a credit search let alone one to a specific standard. What this does mean is that Steadypay may not have seen all the information that Mr C can see in his own credit report – this maybe because Steadypay only asked for certain pieces of information. But what Steadypay couldn’t do was carry out a credit search and then not react to the results it received. The credit results showed that Mr C already had outstanding loan balances of £1,300 – which isn’t particularly high. He didn’t have any defaults recorded against him within the last three years, neither did he have delinquent accounts recorded on his credit file within the last year. These credit check results wouldn’t have suggested to Steadypay that Mr C was having or likely having financial difficulties. I can see from the notes provided by Steadypay that not long after the facility was opened it was contacted by a third party to discuss Mr C’s debt. This does suggest that Mr C’s finances were more precarious at the time than the data received, and used, by Steadypay suggested. But Steadypay could only make its decision to lend based on the information that it asked for and what it received. Taking account, the monthly repayment that Mr C would be contracted to pay I’m satisfied the checks carried out by Steadypay were commensurate with that. As such, Steadypay made a fair lending decision, and I am not upholding Mr C’s complaint about its decision to provide the facility. Help and support in repaying the balance I’ve briefly dealt with this section because I’m minded that in response to the Investigator’s assessments Mr C’s main concerns are around the payment problems up to December 2024 and then the CPA issues that occurred after then. Not long after Mr C was granted the facility, a third party, acting on his behalf contacted Steadypay to try and negotiate a payment plan – this happened from the middle of October 2024. I understand that Mr C said he didn’t expect payments to be attempted in this period – while payments were attempted – these were unsuccessful. So even if Mr C wasn’t expecting the payment attempt to be made – nonetheless nothing was collected from him. The original offer made by Mr C’s representative, was to pay Steadypay £5 per month – but the offer was then increased to £5.90 per month. Steadypay says it rejected these offers because it would’ve taken too long for the balances to be repaid – over five years. Instead, Mr C has said that it wanted around £65 per month which was more than the other creditors were getting – and Mr C agreed to take on and deal with this facility himself. Although, I don’t know the date when Mr C decided to take this on – given the chat I’ve seen this was likely around the middle of November. I’ve thought about whether this was fair – because Mr C says that while the plan was being discussed all of the payments that were due to be put on hold. I can see from the regulations that Steadypay could suspended the recovery of a debt owned while a plan is being

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discussed. But I’ve not seen anything to suggest that once Steadypay declined to accept the offer of payment that it wasn’t entitled to ask Mr C to make the payments. And given the way the facility is structured, the capital balance wouldn’t grow for example in late fees or additional interest – instead it would just additional monthly membership fees. So, I don’t think there has been any financial loss caused to Mr C – whether Steadypay made a mistake or not in trying to collect payment in October 2024. I’ll come onto below about the problems Mr C had making payments through the app but a plan was agreed with Mr C to pay down the capital balance plus pay a total of three months membership fees – so a total of £390. By doing this, Steadypay agreed to not charge another two months membership fees. While Mr C held the account for five months only three months fees were charged. I consider this to be fair and reasonable, and while I’ve noted Mr C has said he wasn’t in a position to make these payments – he did agree to the terms of the plan Card payments problems Firstly, I’m just going to set out what I can see from the evidence provided – in summary Mr C’s original card – connected to his current account where he was paid into at the point the facility was approved was declined a number of occasions when Steadypay attempted to take the payments that he was contracted to make. As a result, the account fell into arrears. Then from 13 December 2024, a new card – from a different current account was added to the account and payments were successfully taken from this card on 13, 16 and 28 December totalling £190. Steadypay attempted further payments on 28, 29, 30 and 31 December 2024 and these were all declined – according to the system this was due to insufficient funds being held into the account. However, Mr C says that he knew there was a problem with the original card and he tried to make payment through the app with the card that was eventually added to the account in December 2024. Mr C told Steadypay on in November 2024 the following; “hello so I click to pay the balance and then I select my card and put my details in and after it says payment received but then takes me back to the homepgage (sic) where it still says the balance is overdue and no money has left me account.” I think at this point, Mr C was trying to use his ‘new’ card details to make the payment and this is how he has described the problem to us in other, later emails. But what I would say is that it’s not immediately clear from the chat history that Mr C was having problems with a new card or indeed a different card to the one Steadypay already held for him in November 2024. Steadypay responded on 18 November 2024, saying Mr C’s bank had blocked the card payments and Mr C would need to contact them to find out what is going on. It is my understanding that Mr C made enquires with his ‘new’ card bank. I’ve also independently asked Steadypay about the chat history from November 2024 – to see if there is any more detail – beyond the chat mentioned above. The only messages it was able to provide were reminders sent to Mr C’s account outlining that there were arrears and there needed to be an arrangement put in place otherwise further adverse information would be reported to the credit reference agencies. All of these messages pre-date the chat history I’ve seen above. They were sent in the first week of November 2024.

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Based on the chat history I have, no further response was received from Mr C indeed, the next message came from Steadypay on 4 December 2024, where a reminder was sent to him about the account being in arrears. Mr C says he was trying to use the new card details to make this payment – but for some reason wasn’t being successful. But I don’t think what was especially clear in the message he sent to Steadypay – Mr C was just saying the payments weren’t going through. So, the information given to Mr C from the agent in November 2024 would’ve appeared accurate because by this point it had tried on a number of occasions to use the card details he provide at the inception of the agreement to make payment, and these hadn’t been successful. Which is backed up by Steadypay’s payment log. There does appear to have been some cross communication – with both parties asking and answering slightly different questions to what was intended. I also asked Steadypay to see whether there had been any reported technical issues with the app around the time Mr C says he was having payment problems. Steadypay has confirmed that there were no recorded or known issues with the app and neither where there any issues impacting card payments at this time. I don’t know why payments weren’t going through, but Mr C was aware of this because Steadypay sent reminders that the account was in arrears. While I acknowledge that Mr C as he asked for Steadypay’s help and support and it agreed to a 30 day hold – I haven’t seen any evidence to support this. Indeed, Steadypay says that no such hold was agreed. In short, while I can see that Mr C was becoming frustrated with the response he was receiving from Steadypay from his emails at the end of December 2024 and January 2025. Where I can see Mr C was having to reiterate the problems, he had experience with the app, that doesn’t mean that Steadypay has made an error which ought to lead to a payment of compensation. I’ve considered the evidence provided and I’m minded that payments by this time had started and it’s not always straightforward dealing with finances business especially where the information provided may not be complete or no longer available. From time-to-time things do go wrong and that was to be expected. And I also think it’s clear that the agent who was discussing these issues with Mr C at the end of December 2024 – still wasn’t entirely sure what Mr C was explaining – because there are reference to the original card – which of course isn’t what Mr C had said there was a problem with. I can’t provide Mr C with an answer as to why the app wasn’t working at the time – but I’m satisfied that eventually, Mr C was able to repay the account – with Steadypay waiving some of the membership fees that could’ve been charged. It’s also clear that Steadypay wasn’t entirely sure about the concerns that Mr C had raised with regard to the payment problems and the app. But overall, I’m not persuaded given everything I’ve seen that Mr C should be paid compensation for this. CPA used from December 2024 Mr C is also unhappy that after he added his new card details in December 2024, these were added to his account and then used by Steadypay to collect further payments from him – which left him short of money in the lead up to Christmas.

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These, payments which I’ve outlined earlier on in the decision were collected by a CPA but Mr C says he didn’t give authorisation to Steadypay to do this and he’s provided a copy of an email received from the bank which is connected to the which said. “We now agree that the payments taken by SteadyPay after your initial £100 invoice payment were unauthorized(sic).” While I’ve noted the content of this email, Steadypay has provided a walk-through guide with screen shots that Mr C would’ve have followed when paying the first invoice in December 2024. He would’ve clicked on the “pay invoice” button which would’ve taken him through to a payment processing screen where his card details were entered. Directly above the “pay” button there was a condition outlined which said; “By confirming your payments you allow STEADYPAY LIMITED to charge you for this payment and save your payment information in accordance with their terms.” Directly, underneath this was a link to Steadypay’s terms and conditions. By following this link, Steadypay sets out that a card is needed to take payments via a CPA and any new card that is added will automatically be saved and therefore be available for payments. Having looked at the terms and conditions as well as other information on the website this is consistent with the approach that Steadypay takes. Mr C may not have intended for Steadypay to take further payments through the CPA, but I’m satisfied from looking at the evidence, that no error was made by Steadypay in relation to this. Account blocking Mr C says he has been blocked from accessing his account as he was unable to log in and as a result, he hasn’t been able to provide evidence of other chats he had with Steadypay agents. Mr C says locking the account is a clear admittance of guilt. Steadypay and Mr C has provided an overview of a number of chats, emails and other letters that have been sent – so I’m satisfied that Mr C’s complaint hasn’t been materially impacted by him not being able to gain access to his account. However, Steadypay that says following the successful repayment of the balance the account was closed on 10 February 2025. Steadypay has said that Mr C then tried to log into the account again on 18 February 2025 but as the account was closed there wasn’t any account for him to log into. I don’t think this was an unreasonable position to take nor is this evidence that Steadypay has made an error. It merely, given what it knew about Mr C, didn’t want him to have further access to funds and so it was correct the account be closed. I do not uphold this part of Mr C’s complaint. Complaint handling The Financial Ombudsman can generally help with most types of complaints – but to be able to do so the activity in question has to be one that has been regulated by the regulator. Unfortunately, the act of complaint handling isn’t a regulated activity and so I can’t consider how Steadypay dealt with Mr C’s complaints. I appreciate this will be disappointing to him, but I can’t make a finding in an area where I have no power to do.

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Finally, I’ve considered whether Steadypay and Mr C’s relationship might have been unfair under Section140A of the Consumer Credit Act 1974. However, for the reasons I’ve already given, I don’t think Steadypay lent irresponsibly to Mr C or otherwise treated him unfairly in relation to this matter. I haven’t seen anything to suggest that Section 140A would, given the facts of this complaint, lead to a different outcome here. I know this outcome will come as a disappointment to Mr C. My final decision For the reasons explained above, I’m not upholding Mr C’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr C to accept or reject my decision before 27 April 2026. Robert Walker Ombudsman

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