TrustTwo Unaffordable Lending Complaints
TrustTwo is a name used historically by two separate UK guarantor lenders — TFS Loans Limited and Everyday Lending Limited (the NSF Group). Both have collapsed in different ways. TFS Loans went into administration in February 2022 and received an FCA fine of £811,900 for affordability failures. The NSF Group ran a Scheme of Arrangement that closed to new claims at the end of 2023. This page explains where TrustTwo complaints stand depending on which entity issued the loan.
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Two TrustTwo entities
The TrustTwo brand has been used by:
- TFS Loans Limited — operated as TrustTwo and TFS Loans. Administration February 2022. FCA fine £811,900 in June 2022 for affordability failures affecting 3,150 guarantors.
- Everyday Lending Limited (NSF Group) — also used the TrustTwo brand alongside George Banco. Stopped new lending November 2020. Scheme of Arrangement court-sanctioned 22 June 2023, £14m fund, claim deadline 31 December 2023.
Customers should check their loan paperwork or original credit agreement to identify which entity issued their loan. The two routes are quite different.
TFS Loans / TrustTwo administration
TFS Loans Limited entered administration in February 2022. The FCA subsequently issued a fine of £811,900 in June 2022, finding that TFS had failed to gather adequate information on guarantors’ financial circumstances — including essential expenses like food, clothing, energy, childcare and medical costs — and instead relied on flawed formulaic approaches that assumed standard household expenditures without proper verification. The FCA found these failures affected approximately 3,150 guarantors who entered into agreements between November 2015 and April 2018.
For TFS Loans / TrustTwo administration:
- Affordability complaints had to be submitted through the administrator’s process.
- Recovery has been limited to whatever distributions the administration can make — generally pennies in the pound.
- No new claims can be brought outside the administration process.
- The standard CONC and FOS route does not apply once a lender is in administration.
NSF Group / TrustTwo Scheme of Arrangement
For TrustTwo loans issued by Everyday Lending Limited (the NSF Group entity that also operated George Banco and Everyday Loans):
- A Scheme of Arrangement was court-sanctioned on 22 June 2023.
- The scheme covered redress claims and FOS fees in their entirety.
- A £14 million scheme fund was made available, with estimated recovery of 22-28% of calculated claim value.
- The claim deadline was 31 December 2023 — claims after that date generally cannot be brought.
- Distributions ran through 2024-2025.
Affordability failures identified by the FCA
The FCA’s 2022 fine notice on TFS Loans set out specific failures that are characteristic of guarantor sector problems generally:
- Failing to collect appropriate information on guarantors’ financial circumstances.
- Relying on formulaic approaches that assumed household expenditures rather than verifying actual ones.
- Treating homeowner status as sufficient evidence of guarantor ability to pay, without considering whether equity could be sustainably accessed.
- Not assessing potential significant adverse impact on guarantors before approving loans.
These same failures were widespread across the guarantor sector, which is why FOS upheld guarantor complaints at exceptionally high rates and why most major lenders ended up in schemes or administration.
Where TrustTwo complaints stand now
For most customers, the practical position is constrained:
- TFS Loans / TrustTwo administration loans — handled through the administration process. Limited recovery.
- NSF Group TrustTwo loans, claim filed before 31 December 2023 — became scheme creditors, distributions complete.
- NSF Group TrustTwo loans, no claim filed before deadline — generally cannot bring affordability complaints now.
- Active loans still in run-off — repayments continue under original agreement; hardship support available from the relevant servicer.
For customers who missed the relevant deadline
For both administration and scheme cases, the route to fresh affordability complaints is essentially closed. Possible alternatives:
- Section 140A unfair relationship court claims — theoretically available but practically constrained.
- Where the original lending was unaffordable but no recovery is now available, the affordability point can sometimes still influence settlement negotiations on any current balance.
- Complaints about post-scheme/post-administration conduct — for issues that arose after the cut-off, separate complaint routes may apply.
What if the lender has gone into administration?.
Frequently asked questions
How do I tell which TrustTwo entity issued my loan?
The original credit agreement should name the lender — either “TFS Loans Limited” or “Everyday Lending Limited” (the NSF Group entity). If you don’t still have the agreement, a Subject Access Request can identify the correct entity.
I missed both deadlines — is anything still possible?
For most missed-deadline situations, the affordability complaint route is closed. The administration and the scheme both compromised existing claims by their respective deadlines. Specific advice on unusual circumstances is sensible.
Related guides
- What if the lender has gone into administration?
- Guarantor loans claims hub
- Section 140A and the unfair relationship test
- How far back can I claim?
- Do I have an unaffordable lending claim?
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