Ad description
Claims on a website for a payday loan company, www.paydaypig.co.uk, under the heading "How it Works" stated "At Payday Pig ® we want to make things as fast, simple and convenient for you as possible. As one of the UK's top loan brokers we have all the UK's top lenders on our panel so you only have to try one place. And because it is all online you could have the money in your account in an hour or two. You never know when an unexpected bill will arrive - a busted boiler, a broken down car, a really big fuel bill. Or maybe you want to treat yourself and a loved one to a weekend away or a slap-up meal. Sometimes payday is just too far away. Whatever the reason, if you decide you want a short-term unsecured loan then you just need to follow these three simple steps". Images of cartoon pigs were featured at the top of each page of the website.
Issue
The complainant challenged whether the images of cartoon pigs, along with the claim "treat yourself and a loved one to a weekend away and a slap up meal" were irresponsible because they trivialised the decision to take out a loan and encouraged frivolous spending.
Response
Stop Go Networks Ltd said it was never their intention to trivialise the decision to take out a loan or to encourage frivolous spending. They said they had merely wanted to show that borrowing money could be used occasionally for positive experiences and not only to deal with negative experiences in life. They said their website contained significantly more than the prescribed warnings required about the need to pay back short-term debt on time and that payday loans were not intended for anything other than short-term borrowing. However, they said that they did not want the message to be misconstrued and they had therefore removed the sentence "Or maybe you want to treat yourself and a loved one to a weekend away or a slap-up meal" from the website.
Stop Go Networks stated that, in the three years that they had been operating the Payday Pig website, they had never had a complaint about the creative treatment used on the website. They pointed out that a picture of their website had been incorrectly published in a national press article about the use of cartoon characters in payday loan ads running alongside children's TV programmes, but said they had never run any TV ads and they suspected that the complaint had been triggered by the misinformation included in that article. They agreed that cartoon characters in TV ads could be misunderstood by children when run alongside children's TV programmes, but stated that that was a practice they had never undertaken, and stated that their advertising was only ever addressed to adults.
Stop Go Networks said the image on their website was based on a piggy bank and therefore its associations with money were well understood. They said piggy banks were used by many institutions to advertise many serious financial products. They said the content on the Payday Pig website deliberately and clearly stressed responsible borrowing, the cost of borrowing and the implications of missed payments in very prominent positions throughout the website.
Stop Go Networks stated that they did not consider the use of cartoon imagery in payday loan ads to be irresponsible. They said cartoons and comics had a long history of being used to address serious subjects and highlighted that most daily newspapers ran political cartoons and were generally solely intended for the adult reader. They said cartoon imagery was used throughout advertising by many institutions to advertise many serious financial products and gave examples of that.
Assessment
Upheld
The ASA considered that taking a high-interest, short-term loan was a step that should only be taken following careful consideration and considered that marketers should take care to advertise those products responsibly.
We noted that the ad featured brightly coloured images of smiling cartoon pigs at the top of each page, including one pig that appeared to have glistening gold coins coming out of its back. Although we acknowledged that consumers were likely to understand piggy banks to be associated with frugal financial planning, in the context of promoting a short-term loan and in light of the fact that the piggy bank appeared to be spilling its contents, we did not consider this connotation to be clear or relevant. We considered that the use of such imagery gave the general impression that the service offered was one that could be approached in a light-hearted manner.
We noted that the ad listed various reasons for needing a payday loan and included text that stated "Or maybe you want to treat yourself and a loved one to a weekend away or a slap-up meal". We considered that for most consumers going out for a meal or for a weekend away would not be considered to be essential or urgent and therefore considered that the reference to using high interest, short-term credit to fund such activities was likely to be seen as encouraging frivolous spending of that borrowed money.
Because we considered that the use of jocular cartoon imagery and the reference to the use of borrowed money to fund a shopping trip or short break away made light of the decision to take out a loan, we concluded that the ad was irresponsible.
The ad breached the CAP Code (Edition 12) rule 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Responsible advertising).
Action
The ad must not appear again in its current form. We told Stop Go Networks Ltd to ensure that their future advertising was prepared with a sense of responsibility to consumers and society.
