Context
ASA has published a webpage relating to a few rulings on ads for products related to ‘debt’, that are not regulated by the FCA, such as IVAs and Lead Generation. CAP has also issued an Enforcement Notice to advertisers which provides guidance about ads placed by lead generation companies and licensed insolvency practitioners.
Key points to note and next actions
Common issues to avoid;
- State any risks and fees involved – Information about any fees that will apply is likely to be considered material, and so would need to be included in the ad. Ads should also avoid implying that services are free when they’re not. Material information is information that the consumer needs to make informed decisions in relation to a product.
- Don’t imply it’s straightforward or guaranteed
- Don’t imply endorsement – Ads should not feature official trust marks without the correct authorisation.
- Evidence any objective claims – Claims such as the amount that can be written off should be representative of what average consumers can achieve. Advertisers would be expected to hold documentary evidence to show any stated amounts are representative.