Ad description
A website ad for short-term loans at www.rudolphsreadies.co.uk, featured a header with cartoon images of Rudolph the Reindeer, Santa and a snowman alongside a Christmas tree with presents underneath, and text which stated "Rudolph's Readies Brighten up Christmas with a £1000 Cash Loan Apply Now". Text in the main body of the web page stated "Bring a little cheer this Christmas. Get a fast Cash Loan up to £1000 Today Christmas is an expensive time of year, with extra heating and food bills as well as those emergencies that seem more common in winter Fast Application > Fast Approval > Fast Cash". Underneath a loan cost calculator, further text stated "Rudolph's Readies offers fast and simple Short Term Loans. There's no paperwork and no phone calls. Simply apply online … we have one of the best acceptance rates in the business. We cover your temporary cash flow problems, helping you avoid bank or credit card charges, or pay unexpected bills when you know payday is just around the corner". A box on the left-hand side of the web page, headed "Fast Cash for Christmas …", summarised the loan application process and featured cartoon images of a snowman next to a computer, an envelope with a card poking out which stated "Xmas", and Santa next to a stack of money.
Issue
The complainant challenged whether the ad was irresponsible, because it trivialised the decision to take out a short-term loan and promoted a casual attitude to using a loan to fund Christmas spending.
Response
Stop Go Networks Ltd t/a Rudolph's Readies said the ad pointed out that short-term loans were expensive and should only be used for emergencies. It clearly stated that their loans would only be suitable for emergency heating and food bills when payday was just around the corner, and also included a representative example in a prominent banner position, along with the text "Warning: Late repayment can cause you serious money problems. For help, go to moneyadviceservice.org.uk", which was required by the Financial Conduct Authority (FCA). They added that the website name, "Rudolph's Readies" had been approved by the Office of Fair Trading (OFT) at the time they were responsible for licensing of their industry. Rudolph's Readies said the purpose of the design used in the ad was to ensure their marketing stood out from their competitors. They said they had disabled the website shortly after being contacted by the ASA.
Assessment
Upheld
The ASA acknowledged the ad included a prominent warning that late repayment could cause borrowers "serious money problems", as well as statements which highlighted that the loans could be used for short-term cash-flow problems and to cover expenses that most consumers would consider to be necessities such as heating and food bills. We also acknowledged Christmas was a time when people might need extra money in order to cover additional costs such as buying gifts so that their children or family had something new to open, extra food to celebrate Christmas Day or travel expenses incurred by visiting family.
Notwithstanding that, the ad prominently featured brightly coloured cartoon images of Santa, a reindeer making the 'ok' sign with its hand and a snowman, all smiling broadly, next to a Christmas tree with presents underneath. Additionally, the section which included a three point summary of the loan application process featured a snowman next to a laptop, an envelope with an "Xmas" card poking out, and a Santa next to a stack of money. Each of the three "Apply Now" buttons on the web page featured a candy cane 'hanging' off it. We were concerned that, in conjunction with statements such as "Brighten up Christmas with a £1000 Cash Loan", "Bring a little cheer this Christmas" and "Fast Cash for Christmas", which were more prominent than the statements referenced above, and with the 'Rudolph's Readies' name, which we considered was a flippant reference in the context of a high interest short-term loan, the cartoon images used in the ad made light of the decision to take out a loan and promoted a casual attitude to using a loan to fund Christmas spending. We therefore concluded the ad was irresponsible.
The ad breached 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.
