funding-refusal

---
name: funding-refusal
description: Turns a declined finance application into a written list of what to fix before you apply again: the decline reason read against the categories a credit decision is actually built from, the statutory bank referral scheme you are entitled to be offered and whether you were, a Companies House and credit file check for anything the lender might have seen, a fix list with a named action and a date against each item, and a record of what you cannot fix because it is the lender's own commercial choice. Use the week after a decline, while the reason is still fresh and the next application is not yet written.
---

# A decline turned into a dated list of what to fix, what to ask for, and what was never yours to fix at all

You give this the declined application, whatever reason the lender gave, your Companies House record, your credit file findings if you have them, and your existing facilities. You get back the decline reason sorted against the categories a lending decision is actually built from, a check of whether the lender was required to offer you the statutory bank referral scheme and whether it did, a fix list naming a specific action and a date against every fixable item, and a separate list of what was not fixable because it was the lender's own commercial appetite rather than anything wrong with the business. It will not tell you why you were really declined. A credit decision is the lender's own assessment, and no document outside that lender can read it.

## What it does

1. **Write down exactly what the lender said, in its own words, before adding anything to it.** Most UK business lending sits outside the consumer credit regime once the credit exceeds £25,000 and is for business purposes, and the FCA's own Consumer Credit sourcebook applies "to a firm with respect to carrying on credit-related regulated activities and connected activities", a scope built around regulated consumer credit rather than exempt business lending. There is no equivalent UK statutory right, for this kind of exempt business borrowing, to a detailed written statement of reasons the way there is in some other jurisdictions. What you are actually owed is often a short sentence, sometimes only "does not meet our current lending criteria." Write that sentence down verbatim, note who said it, when, and by what channel, because a vague reason is itself a data point about how much explanation this particular lender is willing to give, and it decides how much of the rest of this file has to be built from your own records rather than theirs.

2. **Check whether the bank was required to offer you the bank referral scheme, and whether it did.** The Small and Medium Sized Business (Finance Platforms) Regulations 2015 place a duty on designated banks: where a small or medium sized business's finance application is declined, "the bank must provide all specified information that it holds in relation to the application to all designated finance platforms", but only where the business has agreed, because the bank "must... ask the small or medium sized business whether it agrees to information being provided." As at 23 September 2026 this duty remains in force: legislation.gov.uk records "no known outstanding effects" against the Regulations, and a government response published in May 2026 confirms the scheme continues on its existing legal footing, stating that "the Government does not believe it prudent at the current juncture to continue with proposals that would require legislative change" and instead calling on the sector to improve the scheme voluntarily. The duty applies to nine designated banking groups: Allied Irish Bank, Bank of Ireland, Barclays, Clydesdale and Yorkshire Banks, Danske Bank, HSBC, Lloyds, Royal Bank of Scotland and Santander. If the decline came from one of these and no referral was offered, that is a specific, checkable failure, not a vague complaint, and it is worth raising with the bank in those terms.

3. **Sort the decline into one of the categories a lending decision is actually built from, using what you know rather than guessing at what you don't.** Adverse credit history, such as an unsatisfied county court judgment or a default. Insufficient trading history for the amount requested. A cash flow or affordability shortfall shown in the figures submitted. Insufficient or unregistered security. A sector or business type the lender's own current risk appetite has stepped back from, which has nothing to do with this specific business. An incomplete or inconsistent application pack. Mark which category the lender's own wording points to, and mark the others as unknown rather than ruled out, because a short decline sentence rarely names only one true reason.

4. **Check the County Court Judgments register for anything a lender's credit search would have found.** The Register of Judgments, Orders and Fines is "the statutory public Register of Judgments, Orders and Fines for England & Wales", maintained by Registry Trust Ltd under contract to the Ministry of Justice, and a judgment "stays on the statutory register for six years unless set-aside/cancelled", whether or not it has since been paid. A judgment that was paid off the day after it was entered still shows on the register as satisfied rather than absent, and it is exactly the kind of finding that produces a short decline sentence with no further detail. Search the company's own name and each director's name, and record what is found with its date.

5. **Check the Companies House record for anything the lender's own review would have surfaced.** Late accounts filing carries an automatic penalty in published bands: "up to 1 month" costs 150 pounds, "1 to 3 months" costs 375 pounds, "3 to 6 months" costs 750 pounds, and "more than 6 months" costs 1,500 pounds, doubled where two consecutive years are late. Beyond the penalty, a late filing marker is itself a visible signal in the public record, checked without any special access. Read the filing history against every deadline that has passed and record any that were missed, because this is one of the few items on this list that is entirely within the owner's power to have already fixed by the time it is read again.

6. **Check the personal credit position of every director where the business has thin trading history, because a young company is often assessed on its owners.** Where a lender's decision leaned on a director's own credit file rather than the company's, that file is the director's to request and check, and the request is free. This skill does not repeat the mechanics of requesting or reading that file, which are covered in the credit-profile skill, but it records here whether that check has been done, because a decline on a start up is frequently a decline on the people rather than the business plan.

7. **Separate what is fixable from what is not, and write both lists with equal honesty.** Fixable: a late filing brought up to date, a satisfied judgment confirmed as such on the register, an incomplete application pack completed, a cash flow forecast rebuilt on sourced assumptions rather than optimism, security offered where none was on the table before. Not fixable by the business at all: a lender's current sector appetite, a lender's minimum trading history policy that this business genuinely does not meet yet, or a lender's internal risk model changing between one application and the next for reasons that were never about this file. Naming the second list stops an owner reapplying to the same door with the same paperwork and expecting a different answer, and it is the more useful list precisely because it says stop rather than try harder.

8. **Where a personal guarantee was asked for and refused, or asked for and it changed the decision, record that as its own line, separate from the credit decision.** A guarantor who has signed one, or who is asked to, can bring a complaint to the Financial Ombudsman Service, which states plainly that it can help "individuals who act as personal guarantors for loans to businesses they're involved in." That right exists whether or not the underlying business borrowing was itself regulated, because the guarantee is a personal undertaking by an individual, a different legal question to the company's own borrowing. Record whether a guarantee was requested, whether it was offered, and whether it played any stated part in the decision.

9. **Hand the register checks, the filing history and the file building to Codex, and keep the reading of the decision and the regulations here.** Write the inputs into a working folder, then run:

   ```
   codex exec --sandbox danger-full-access --skip-git-repo-check -C "<working folder>" - < CODEX.md
   ```

   Claude hands over the decline wording verbatim with its date and source, the lender's name and whether it is a designated bank, whether a referral was offered, the Companies House filing dates, any County Court Judgment search results with their dates, and the owner's marks on which categories the reason points to. Codex returns the filing history table with any penalty band, the referral scheme check, the categorised reason table, the fix list with a status column, and the gap list. Codex never marks a category as the true reason; it records what the lender said and what the public record shows.

10. **Set a date to reapply, and do not reapply before every item on the fix list is either done or explicitly accepted as unfixed.** Put the date the decline was received, the date every fix was completed, and the earliest date the file supports another application. A second application sent the same week as the first, with the same gaps, reads to a lender as the same file twice.

## Then it checks

1. The lender's stated reason is recorded verbatim with its date and channel, and no invented reason is added to it.
2. The file states whether the lender is one of the nine designated banks and, if so, whether the statutory bank referral offer was made, with the outcome recorded either way.
3. The County Court Judgments register has been searched against the company name and every director's name, with the date of the search and what was found.
4. The Companies House filing history has been checked against every deadline that has passed, and any late filing states the applicable penalty band.
5. The fix list separates fixable items with a named action and a date from items recorded as not fixable by the business, and no item appears on both lists.
6. Where a personal guarantee was requested or discussed, it is recorded as its own line with whether it was offered and whether it was stated to affect the decision.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never state a typical decline rate, a normal reason for refusal across the industry, or an average time before a reapplication succeeds. No published figure exists for a single independent UK hospitality business, and a borrowed statistic turns a specific, fixable file into a general story that explains nothing.
- Never predict whether a future application will succeed, even after every item on the fix list is closed. A closed fix list removes a reason to decline. It does not create a reason to accept.
- Never present a lender's decline as a verdict on the business as a whole. A decline is one lender's decision under its own current criteria, applied on one day, and it is recorded as exactly that and nothing more.
- Never assume a decline was unlawful or discriminatory without evidence, and never draft such a complaint. Where the pattern looks wrong, that is a question for the owner's own solicitor, not a conclusion this file reaches.
- Never treat a personal guarantee request as part of the credit decision to be fixed. Whether to offer or sign one is the owner's decision, made with their own solicitor, not an item on the fix list.
- This output is a working document prepared for the owner to check against their own correspondence, Companies House filings and any credit file findings, and for their own accountant to review before a fix list item is relied on in a new application. Where a personal guarantee is involved, or the owner believes the decline itself was unlawful, it is also for their own solicitor and, where the lending would be regulated, an FCA authorised adviser. It is not advice and it is not a statement that any future application will succeed.

## Built from
- The Small and Medium Sized Business (Finance Platforms) Regulations 2015, regulations 3 and 4, https://www.legislation.gov.uk/uksi/2015/1946/body/made, read 23 September 2026, status confirmed at https://www.legislation.gov.uk/uksi/2015/1946/contents as carrying no known outstanding effects, read 23 September 2026: the bank referral duty and the consent requirement in step 2.
- HM Treasury, "Government response: access to finance policy, commercial credit data sharing and bank referrals", published May 2026, reported via https://www.regulationtomorrow.com/2026/05/government-response-access-to-finance-policy-commercial-credit-data-sharing-and-bank-referrals/, read 23 September 2026: confirmation that the scheme continues on its existing legal footing without legislative change, in step 2.
- GOV.UK, "Small and Medium Sized Business (Finance Platforms) Regulations 2015: information sheet", https://www.gov.uk/government/publications/designation-of-banks-and-finance-platforms-for-finance-platforms-regulations/small-and-medium-sized-business-finance-platforms-regulations-2015-information-sheet, last updated 1 March 2018, read 23 September 2026: the list of nine designated banking groups in step 2.
- FCA Handbook, CONC 1.2, https://www.handbook.fca.org.uk/handbook/CONC/1/2.html, read 23 September 2026: the scope of the Consumer Credit sourcebook to credit-related regulated activities, behind the absence of a statutory reasons requirement for exempt business lending in step 1.
- Registry Trust Ltd, "The Registers Explained, England and Wales", https://www.trustonline.org.uk/help-topics/the-registers-explained-e-and-w/, no publication date shown on the page, read 23 September 2026: the six year retention of a County Court Judgment on the statutory register in step 4.
- Companies House and GOV.UK, "Prepare annual accounts for a private limited company: penalties for late filing", https://www.gov.uk/annual-accounts/penalties-for-late-filing, no publication date shown on the page, read 23 September 2026: the four penalty bands in step 5.
- Financial Ombudsman Service, "Who we can help", https://sme.financial-ombudsman.org.uk/complain/can-help, no publication date shown on the page, read 23 September 2026: personal guarantors as eligible complainants, in step 8.

# funding-refusal

## You are given
One UK business whose finance application has been declined. The lender's name, the product applied for, the amount, the date of the decline, the channel it arrived by, and the lender's stated reason copied verbatim. Whether the lender is one of the nine designated banks under the bank referral scheme, and if so, whether a referral to a designated finance platform was offered and, if offered, whether the business agreed to it. The company's Companies House filing history: every accounting reference date and accounts filing date, and every confirmation statement due date and filing date. Any County Court Judgment search result against the company name and each director's name, with the search date and what was found, or a statement that no search has yet been done. The owner's marks against each decline category, stated as pointing, not pointing or unclear, with a reason beside each mark. Whether a personal guarantee was requested, whether it was offered, and whether the lender stated it affected the decision. All judgement calls, including which category the true reason falls into, have already been made by the owner and are supplied to you.

## Produce
Write into a `./funding-refusal-output/` folder:

1. `decline-record.md` recording, on separate lines and nothing else: the lender name; the product and amount applied for; the decline date and channel; and the reason copied verbatim in quotation marks.
2. `referral-scheme-check.md` recording, on separate lines and nothing else: whether the lender is one of the nine designated banks, stated `yes` or `no`; where `yes`, whether a referral was offered, stated `offered`, `not offered` or `not stated`; and where offered, whether the business agreed, stated `agreed`, `declined` or `not stated`.
3. `filing-history.csv` with columns: `filing_type`, `period_or_reference_date`, `deadline_date`, `filed_date`, `days_late`, `status`, `penalty_band`, `penalty_amount_gbp`. `filing_type` is exactly one of `annual accounts`, `confirmation statement`. `status` is exactly one of `on time`, `late`, `not yet due`, `not filed`. `penalty_band` applies only to `annual accounts` rows and is exactly one of `up to 1 month`, `1 to 3 months`, `3 to 6 months`, `more than 6 months`, `not applicable`, with `penalty_amount_gbp` set to 150, 375, 750 or 1500 accordingly, doubled where the owner has supplied that the previous year was also late.
4. `ccj-check.md` recording, on separate lines and nothing else: the search date; the names searched; and the result for each, stated as `none found`, or the judgment amount, date and satisfied status exactly as found.
5. `decline-categories.csv` with columns: `category`, `owner_mark`, `owner_reason_verbatim`. One row for each of exactly these eight categories in this order: `adverse credit history`, `insufficient trading history`, `affordability or cash flow shortfall`, `insufficient or unregistered security`, `sector or business type risk appetite`, `incomplete or inconsistent application`, `personal guarantor credit position`, `reason not stated by lender`. `owner_mark` is exactly one of `points to this`, `does not point to this`, `unclear`.
6. `fix-list.csv` with columns: `item_ref`, `category`, `description_verbatim`, `fixable_by_business`, `action_verbatim`, `target_date`, `status`. `item_ref` is F001 upward. `fixable_by_business` is `yes` or `no`. `status` is exactly one of `not started`, `in progress`, `done`, `accepted as unfixed`. Every row with `fixable_by_business` set to `no` has `action_verbatim` and `target_date` left empty.
7. `guarantee-position.md` recording, on separate lines and nothing else: whether a personal guarantee was requested; whether it was offered; and whether the lender stated it affected the decision, each stated exactly as supplied.
8. `gaps.md` a numbered list of: every filing history row with a missing deadline or filed date; a CCJ check with no search date recorded; every decline category marked `unclear`; every fix list item with `fixable_by_business` set to `yes` and no `target_date` supplied; and any supplied text containing an em dash character.

## Rules
- Codex tests dates, calculates penalty bands and records what was supplied. It never decides why the application was really declined, never marks a decline category as the true reason, and never estimates a filing date or a CCJ search result.
- Never write a benchmark figure of any kind into any file: no typical decline rate, no average number of applications before success, no normal reason for refusal across the sector. None exists for a single independent UK hospitality business and none is to be recorded.
- Never write any statement, in any file, predicting whether a future application will succeed, even where every fix list item reads `done`.
- Never mark a fix list item `fixable_by_business` as `yes` where the owner's own category mark was `does not point to this` or `unclear`. Only items tied to a category the owner has marked as pointing to the reason are treated as fixable.
- Never record a personal guarantee decision as part of the fix list. `guarantee-position.md` records the facts as supplied and nothing more.
- Use British English, GBP written as `GBP` or the pound sign, and DD Month YYYY dates. No em dash characters in any file you write, and any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every quoted lender statement, filing status and CCJ record is copied exactly, including its punctuation and capitalisation.
- Every file ends with this line: this is a working document prepared for the owner to check against their own correspondence, Companies House filings and any credit file findings, and for their own accountant to review before a fix list item is relied on in a new application. Where a personal guarantee is involved, or the owner believes the decline itself was unlawful, it is also for their own solicitor and, where the lending would be regulated, an FCA authorised adviser. It is not advice and it is not a statement that any future application will succeed.

## Return
The absolute path of every file written, the row count of each CSV, the decline reason verbatim, the referral scheme check result, the filing history status counts with the total penalty figure from filing-history.csv, the CCJ check result, the count of decline categories marked points to this, the fix list count split by fixable_by_business yes or no and by status, the guarantee position as recorded, and the gaps.md item count.