Possible discrimination from a housing association…

Janemet

I will keep it simple,

•My husband and I applied for shared ownership on a home with a housing association.

•I’m registered disabled.

•we passed all the affordability and eligibility checks.

•we secured a mortgage for our share.

•we have a deposit and reservation fee.

•the housing association declined us purely on negative markers on our credit file.

•they would not take it into consideration at all due to circumstances, even though the markers were related to my disability when I stopped working and became disabled. But since then we have been trying to get ourselves into a better financial position.

I complained as I believe they did not take my disability into consideration by making reasonable adjustments in line with the equality act 2010. They have argued this and have said their policy states no adverse credit- but they have NOT made any reasonable adjustments, or heard my voice trying to explain this. So much stress has been caused by this. I will post their response to my first complaint. I’ve escalated to second stage.
In planning on taking legal action as it’s so unfair how they have treated someone who is vulnerable and I would hate for it to ever affect another person the same way it has with me.

Has this got grounds for indirect discrimination? Here’s their response-

Firstly, I would like to thank you for allowing me the opportunity to resolve your concerns. I am

sorry to hear that our services have not met your expectations.

During our telephone conversation on 13 November 2025, you confirmed that you wanted me

to look into your concerns as a formal complaint.

During this call you confirmed that there are vulnerabilities in your home, your disability, and I have

taken these into consideration whilst exploring your complaint.

I formally acknowledged your complaint by email/letter on the same day.

I understand your complaint is regarding.

• You are unhappy with the decision of your Shared Ownership Application being refused

following credit checks.

As a resolution you would like.

• Your application to be approved after taking into consideration your disabilities, rent

payment history and challenging your credit report.

Whilst considering your complaint, I have:

• Reviewed the communication logs throughout this period.

• Spoken to the staff involved.

• Reviewed the relevant policy and procedures and considered if they have been adequately

applied.

• Reviewed any other documents available relating to this issue.

• Considered your individual circumstances and if there is any additional support we can

offer you, or anything else I can do to resolve this matter to your satisfaction.Having considered your complaint, I acknowledge your comments and understand your concerns,

and I am sorry for any disappointment or upset this situation has created.

Thank you for taking the time to speak with me recently. Following our conversation, I have

reviewed all the emails you sent to believe housing regarding your complaint, along with the details

of your Shared Ownership (SO) application.

During our discussion, you confirmed that you had read believe housing’s Shared Ownership

Sales Policy and the information provided on GOV.UK. As outlined in these documents, the

decision to accept an application ultimately rests with the provider in this case, believe housing.

Application Assessment Process

The initial assessment stage is designed as a high-level check to ensure applicants are likely

to purchase the minimum share for a new Shared Ownership home (or the share available on

resale) and meet the provider’s policy requirements. At this stage, the information required is not

as detailed as what is needed for the full affordability assessment, which takes place during the

Stage 2 review.

It was only during the Stage 2 assessment, when your full credit report and supporting

documentation were provided that we became aware of your credit history and we refused your

initial application.

Credit checks protect individuals by preventing over-indebtedness and promoting responsible

lending, meaning that affordability assessments, typically via credit reports, are mandatory for

regulated lending.

Shared Ownership Policy Requirements

Believe housing’s Shared Ownership Sales Policy includes the following criteria for applicants:

• No missed mortgage or rent payments within the last 12 months.

• Bankruptcy discharged more than three years ago (subject to individual assessment).

• No unsatisfied County Court Judgements (CCJs) within the last 36 months.

• Individual Voluntary Arrangements (IVAs) discharged more than three years ago with no

residual debt (subject to individual assessment).

• No late payments in the last six months.

The policy also states that believe housing reserves the right to decline an application based on

the type and number of adverse credit entries, the total financial amount, and when these were

registered.

Credit Report Concerns

You explained that one entry on your credit report was incorrect due to a lender mistakenly

recording an action as a missed payment. I understand you have contacted the lender and agreed

to settle the account and they have confirmed they will correct the error.

Please ensure this amendment is completed, as settling the account alone may not automatically

update the disputed entry.

If you believe other information on your credit report is inaccurate, I recommend contacting the

relevant lenders and credit reference agencies (Experian, Equifax, TransUnion) to dispute these

points.Providing supporting documentation and monitoring for corrections can help improve your credit

profile. You may also consider adding a Notice of Correction for accurate complex circumstances.

Joint Application Considerations

From the submitted credit reports, we noted an active County Court Judgement and other adverse

entries on both your credit file. As this is a joint application, these factors must

be considered when assessing affordability and sustainability of payments under the Shared

Ownership scheme.

Unfortunately, based on the information available, we cannot confirm with confidence that both

of you would be able to maintain the required mortgage and rent payments as outlined in

our Shared Ownership Sales Policy.

Equality Act Considerations

You shared that your financial difficulties were linked to ill health, which led to leaving employment

and claiming Personal Independence Payment (PIP) in August 2023.

We have considered this information carefully and applied guidance in line with the Equality Act

2010.

Believe housing assesses all Shared Ownership applications impartially and consistently, ensuring

no applicant is disadvantaged under Homes England’s guidance.

You also asked if reasonable adjustments regarding your credit report were considered and

applied to your situation, I can confirm TMP received all documentation you supplied including your

PIP Award Letter and took this into account in processing your application.

If you remain dissatisfied with this decision, regarding the Equality Act 2010, you may wish to seek

advice from the Citizens Advice Bureau regarding the 2010 Equality Act.

Alternative Options

To provide you with further options in your application I also explored whether the HOLD (Home

Ownership for People with Long-term Disabilities) scheme might be suitable for you. However,

based on your current PIP award, this option may not apply.

I hope this explanation provides clarity on the decision and next steps however, I acknowledge that

this may not be the decision you have hoped for.This now concludes Stage 1 of our complaints process. I am sorry that you had to complain to us,