Think Money Limited · DRN-6253281

The complaint Mrs W complains that Think Money Limited (‘Think Money’) declined to refund her for payments which debited her account which she says she did not make or otherwise authorise. What happened I wrote to both parties in February 2026 with a provisional decision. The following is an extract from that provisional decision. "The circumstances of this complaint are well known to both parties, so I will not go into every detail of what happened here. But, in summary, in 2023 Mrs W says she noticed transactions on her Think Money account which she did not make or otherwise authorise. Mrs W said she initially noticed transactions for a taxi/delivery service which she said she had never used. Around this time, it became apparent that someone had changed the mobile phone number listed to her account. Whilst this was being investigated by Think Money, further unrecognised transactions left her account to a hotel booking website. She froze her card through the app, but then a further charge left her account to the hotel booking website. When her salary came in, £1,000 was sent through an online payment system. Mrs W said she tried to block the entire account, but unable to get through to Think Money, she did this online. Mrs W explained that a third-party had been living with her and her son. She said when this person, who I will refer to as ‘A’ left their address in late 2023, they discovered that possessions were missing from the house and that A had been hiding mail including bank statements. Mrs A reported what had happened to the police and again raised the matter with Think Money. Think Money looked into what had happened and declined to refund Mrs A the disputed transactions. It said that it recognised some failings in ancillary matters such as the customer service it had provided in phone calls and in incorrectly advising Mrs W that she must have been the one who changed the mobile phone number on her account. It awarded £60 for these failings. It said that when the number was changed, it would have required her details such as her telephone passcode and email address. A new card was requested at this time. It said it could not establish who carried out the transactions on the new card. It said the taxi/delivery company transactions dated back to 2020, and the other disputed transactions took place in November 2023, on a card sent to her in November 2023, when A was said to have left the property in that October. Unhappy with Think Money’s response, Mrs W escalated her concerns to our service. One of our investigators looked into what had happened and recommended that Mrs W’s complaint was upheld. They said they thought that Mrs W had not authorised the transactions, nor had she failed with gross negligence to keep her card and security details safe. They said that Think Money should reimburse the disputed transactions, along with 8% simple interest from the date of the loss to the date of the payment, and to ensure the compensation which had already been awarded to Mrs W be paid in full if it had not already been done.

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Think Money did not agree. It said that the further disputed transactions took place on a new card that only Mrs W had access to and the device set up on Mrs W’s phone. So it did not understand how we had concluded that these could be unauthorised. As no agreement could be reached, the case has been passed to me to decide. What I’ve provisionally 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. If nothing changes, my final decision would likely be along the following lines. Can Think Money fairly treat the disputed payments as authorised by Mrs W? The starting position in line with the relevant legislation – The Payment Services Regulations 2017 (PSRs) – is that Think Money would be liable for any unauthorised payments, and Miss P is liable for any payments which she authorised. Authorisation includes authentication, and consent to the payments. I take it from Think Money’s response to our investigator’s view of this complaint that the payments which they are continuing to defend as authorised are the payments which took place after the A left Mrs W’s address. But, for completeness, I have considered all of the payments. Disputed transactions when the third party was living at the address Mrs W has living with A over a number of years. It is clear from the evidence that I have reviewed that this ended acrimoniously and has caused Mrs W a great deal of stress – I was very sorry to read about what she was put through. I understand that the matter is under review by the police due to the actions of A. It does appear that A used duplicitous methods in order to keep Mrs W in the dark about matters relating to her Think Money account. I think it is more likely than not that it was A who changed the phone number linked to Mrs A’s account. A has also been found by the police to have entered into an agreement with the postal service to ensure that they would collect Mrs W’s mail, rather than it going to her address. This meant that Mrs W did not receive any communications relating to her Think Money account for this period, and prevented her from noticing activity on her account. A, living under Mrs W’s roof, had access to everything she required to make transactions on Mrs W’s Think Money account and to make changes on her account. I think it is reasonable to assume your home is a safe place to keep your card and security information – and so it would not be unusual to keep things like her card or security information in places in the home which A could have accessed. This means there is a clear and plausible point of compromise for everything A needed to undertake the transactions here. And Mrs W has been consistent in her testimony that she did not allow A to use her card or account – and there is nothing I have seen from this period which would undermine this testimony. So I think it is most likely that A used her position of privilege in living with Mrs W to get the card and security information in order to change the phone number, organise the post setup, and then used the card when she wished to. So, considering the evidence provided by Mrs W and the police, I think it is more likely than not that the payments in dispute whilst A still lived at Mrs W’s address were not authorised by her – and so Think Money ought to be liable for these. Disputed transactions when the third party no longer resided at the address The question of the disputed transactions after A left the address is where my opinion, at present, differs from that of our investigator. I know this will likely come as a disappointment to Mrs W, and I am sorry for this. But, if nothing changes, I am currently not minded to ask Think Money to reimburse these transactions. I will explain why.

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The card details which were used to make the payments after A left Mrs W’s address were brand new, and Mrs W confirmed she had the card in her possession. Mrs W has admitted there was no way that A would have had access to this card. The online banking app was registered – and this was done by approving it through Mrs W’s mobile phone. Mrs W said that at the time that the one-time passcode (OTP) was sent to her mobile phone, she was at home alone. Considering all of this, I am unable to establish how A or another third party could have accessed her card and her mobile phone, which would have been required to make these disputed transactions. Based on this, I am unable to see how they were authorised by someone other than Mrs W, and so in line with the PSRs, I think Think Money can fairly hold her liable for these transactions. Can Think Money fairly say that Mrs W acted with gross negligence in failing to keep her account safe? Customers have a duty to keep their account safe, including protecting things such as their card, PIN and security information. In some circumstances, firms such as Think Money would not have to reimburse customers who failed to do so – on the basis that they had acted with gross negligence. There is not an exact definition to follow for gross negligence – but it is generally agreed to mean beyond ordinary carelessness, and includes a serious disregard or indifference to an obvious risk. The bar for gross negligence is a high one. I have to consider whether I think Mrs W’s actions amounted to gross negligence with regard to the payments I have said Think Money are liable for. Having done so, I do not think it would be fair or reasonable to say that Mrs W failed to keep her card and security details safe here. This is because, as I have outlined above, I think it is reasonable for someone to assume that they can keep these things safely in their home. A was a trusted person who lived with Mrs W – and so she would have had access to all areas of the home. I do appreciate that one could argue Mrs W should have kept a closer eye on her account, but I do not think this amounts to gross negligence. She was able to make transactions when she needed to – A was not draining the account such that she could not. And I am unaware of anything that would have meant she needed to urgently look at her account, such that she should have noticed that her statements had stopped arriving. So, I am not currently minded to say it would be fair and reasonable for Think Money to say she acted with gross negligence in failing to keep her account safe – and so it follows that Think Money should reimburse the disputed transactions prior to A leaving Mrs W’s address, along with 8% simple interest from the date of the losses to the date of the reimbursement. I would also ask Think Money to ensure that all compensation which has already been awarded has been paid in full if it has not already done so.” 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. Think Money did not respond with any further comments or evidence with regard to my provisional decision. Mrs W did provide a rebuttal, which I will summarise. Mrs W was not happy that I can provisionally concluded that she made or otherwise authorised the payments after A left the address. Mrs W said that she had taken steps to block her account five days after the first hotel website payment left it, and did not unblock the account before the payments left her account. She provided text messages about the account block. She wanted a clear explanation as to how it was unblocked or the payments were processed despite the block. I have carefully considered what Mrs W sent in to our service, but this does not change the overall outcome I am afraid.

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If a payment has already been authorised before the account or card was blocked, the money will generally still leave the account. An authorisation is a guarantee to the merchant that it will be paid. So the payments in this case that left the account after she blocked it had already been made and authorised beforehand. The block would stop any transactions initiated after it was put in place. Putting things right In order to put things right Think Money must now: • Reimburse the disputed transactions which took place in the time A was living at Mrs W’s address; and • Pay 8% simple interest on those payments from the date of payment to date of settlement. My final decision I uphold this complaint, in part, and require Think Money Limited to reimburse Mrs W in line with what I have outlined above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs W to accept or reject my decision before 23 April 2026. Katherine Jones Ombudsman

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