FCA censures Amigo for weak affordability checks; £72.9m fine not imposed

Amigo Loans Ltd · Guarantor consumer lending

Regulatory breachGovernance failureUnit economics

The case in brief

Visible before detection

Checks that could have surfaced it, on hindsight

Would have modelled the loan book with guarantor calls and expected redress.

Can mislead when: Cost allocation is a judgement call. Kubr shows its assumptions and lets the user change them.

Would have tested underwriting and affordability checks on a sample of loans.

Can mislead when: Contract staff do not appear in EPFO. Vahan access needs licensed APIs. Some businesses have no physical trace.

Would have surfaced FCA and complaint records.

Can mislead when: Court records lag and name spellings vary. A clean record can mean the problem has not reached court yet.

Would have flagged lack of response to internal audit.

Can mislead when: Private companies file late, so these signals are lagging. Kubr uses them to support other flags, not to prove anything alone.

Where Kubr services would have helped

Offered in India

Offered in India

C8 Would have surfaced FCA and complaint records.
C10 Would have tested underwriting and affordability checks on a sample of loans.
C11 Would have flagged lack of response to internal audit.

Offered in India

Offered in India

C9 Would have modelled the loan book with guarantor calls and expected redress.
C10 Would have tested underwriting and affordability checks on a sample of loans.

Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.

Same pattern

India · 2025