Cashfloat Unaffordable Lending Complaints
Cashfloat is one of the longest-established post-FCA-regulation UK payday lenders, operating since 2014 as a trading name of Western Circle Limited. The FCA price cap on high-cost short-term credit applies to Cashfloat lending, but very high APRs are still possible within the cap. Where Cashfloat lending was unaffordable for you, the standard CONC and FOS complaint route applies. Western Circle Limited (FRN 714479) is FCA-authorised and active.
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About Cashfloat
Cashfloat is a trading name of Western Circle Limited (company number 7581337, FRN 714479). The lender has operated continuously under FCA regulation since 2014 — opening just as consumer credit moved from the Office of Fair Trading to the FCA. Key features:
- Payday loans £300-£1,500 over 3-9 months.
- Personal loans up to £2,500.
- Representative APR around 611.74% on the payday loan product (subject to the FCA price cap).
- Maximum APR up to 1,294% within the price cap.
- Soft credit search initially, with a hard search only at funding stage if the customer proceeds.
- Continuous payment authority for repayments.
- Member of the Vulnerability Registration Service.
- Has supported over 500,000 UK customers since 2014.
The FCA price cap
Since 2 January 2015, the FCA has imposed a price cap on high-cost short-term credit (HCSTC) — loans defined as having an APR over 100% and a duration of 12 months or less. The cap has three limbs:
- Initial cost cap — interest and fees capped at 0.8% per day of the amount borrowed.
- Default fee cap — fixed default fees capped at £15.
- Total cost cap — total amount payable (including interest, fees and default fees) cannot exceed 100% of the amount borrowed.
Cashfloat operates within these caps. The price cap doesn’t replace the affordability obligation — it sets a ceiling on cost, but the lending must still be affordable for the individual borrower under CONC 5.2A.
Affordability under CONC
Cashfloat must carry out a reasonable and proportionate creditworthiness assessment before each loan. Common issues that arise in payday loan complaints:
- Repeat lending without proper reassessment — multiple loans rolling over with the same lender, indicating the original loan was used to manage existing distress rather than meet a one-off need.
- Borrower already in difficulty — multiple payday loans visible on credit file, recent defaults, gambling activity, returned direct debits.
- Income verification not proportionate — declared income relied on without verification.
- Vulnerability indicators missed — health, mental health, recent life events not factored in.
- £10 missed payment fees compounding small balances — particularly where forbearance under CONC 7 should have been the route.
The Wonga / payday lender pattern
The mass FOS upholds against Wonga (which collapsed into administration in 2018), Sunny (Elevate Credit), Lending Stream, QuickQuid (CashEuroNet) and others established a clear pattern across the payday sector — affordability checks on repeat lending were inadequate, and complaints succeeded at high rates. Cashfloat operates within the same regulatory framework, and similar issues can arise where the affordability assessment was inadequate. The advantage for Cashfloat customers is that Western Circle remains active and able to pay full redress, unlike the collapsed sector competitors.
How a claim works
- Eligibility check on the loan and your circumstances at the time.
- Subject Access Request to Cashfloat covering the lending decision data and account history.
- Bank statements (3 months before and 3 months after the loan) — these are the strongest evidence of affordability.
- Statutory credit report.
- Complaint to Cashfloat — they will acknowledge within 5 working days and aim to provide a Final Response within 8 weeks.
- Escalation to the Financial Ombudsman if the response is unsatisfactory.
- Redress if successful — refund of interest and charges, 8% statutory interest, removal of adverse credit-file entries, balance offset.
Frequently asked questions
I had multiple Cashfloat loans — do I complain about all of them?
Yes — a complaint can cover multiple loans, and the affordability assessment is run across the pattern. Where several loans were taken over a short period, the proportionality threshold for fresh assessment was particularly high, and complaints often succeed across the pattern.
Cashfloat collected by CPA — what about return fees from my bank?
CPA attempts that fail because the account was empty can produce returned-payment fees from the customer’s bank. These are not directly refundable from Cashfloat, but where the underlying lending was unaffordable, the wider financial harm is part of the complaint context. FOS will sometimes consider this in calculating compensation for distress.
Related guides
- Payday loan claims
- The CONC rules on affordability
- How the Financial Ombudsman handles unaffordable lending complaints
- How a claim works step by step
- Do I have an unaffordable lending claim?
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