In July 2014, in response to concern across society, BCAP announced a review into payday loans advertising on television. The review was confined to examining the effectiveness of the content rules to protect children. BCAP also welcomed any submissions of relevant evidence of a need for scheduling restrictions, which it committed to consider.
BCAP’s terms of reference for the review set out its objectives in detail. BCAP’s review assessed:
- Whether payday loans advertising appearing on television broke BCAP’s rules designed to protect children.
- Whether techniques and styles used in ads that fell short of breaking the rules unduly appealed to children.
- 1.2 Advertisements must be prepared with a sense of responsibility to the audience and to society.
- 5.9 Advertisements must neither directly exhort children to buy a product or service nor encourage them to ask their parents, guardians or other persons to buy or enquire about a product or service for them.
BCAP carried out an analysis of a sample of payday loan ads against the relevant content rules. BCAP looked at all TV ads for payday loans for three separate, non-consecutive months spread across 2013 and 2014. It carried out an assessment of whether any of the ads would break rules 5.9 or 1.2. It also considered whether any ad raised concerns falling outside these rules.
The review found a wide variety of treatments used in the ads. Many treatments had the potential to appeal to children in some way, but only because they were of broad appeal. Examples of these treatments included: songs, animated characters, puppets and jingles.
An overall assessment of the ads did not suggest that there was a need for changes to the BCAP Code. However, a common factor noted was that light-hearted, jovial treatments could trivialise the taking out a loan. Such treatments can and have broken the social responsibility rules. In June 2015, CAP and BCAP published guidance on such treatments to reduce the likelihood of ads trivialising loans.