Ad description
A paid-for Facebook ad for Family Vision, a “rent-to-own” credit broker, seen in December 2024. The ad featured a carousel of images in the style of an advent calendar displaying products including games consoles and a TV. Underneath each image was a clickable button labelled “Shop Now” beside text that read “Shop Christmas gifts!” and “Christmas Shopping for all”. The accompanying text stated “Christmas shopping just got more affordable…shop the gifts you want with monthly financing through Family Vision. Ask our experts about financing options for the products you’ve been wanting, from iPads to new home furniture and much more!”
Issue
The ASA challenged whether the ad was socially irresponsible, because it encouraged consumers to spend more than they could afford by taking out credit agreements to fund Christmas spending.Response
Family Vision Ltd said they had removed the ad on receiving notification of the ASA’s investigation. They said they were regulated by the Financial Conduct Authority and offered legitimate credit lines to customers who might otherwise not be able to afford key events such as Christmas.
Family Vision explained they carried out thorough affordability checks to ensure that customers would be able to repay the loan alongside their priority living expenses. They stated that they had a large number of repeat customers, which they believed demonstrated that they were a trusted company. They highlighted that they had a number of steps to ensure customers did not take out loans they could not afford, including creditworthiness assessments, risk reviews and verbally explaining pre-contractual information to each potential consumer to give them the opportunity to ask questions. They said they regularly asked customers to notify them if their circumstances changed or they became financially vulnerable. They cited customer satisfaction surveys which they believed showed they did not intentionally encourage irresponsible borrowing.
Family Vision acknowledged that the ad encouraged customers to obtain finance. However, they did not believe the ad was irresponsible due to the processes they implemented to protect against unaffordable lending. They explained that they would rather customers obtained credit from a company that would offer support if their circumstances changed than illegal lenders who would have a detrimental impact on the financially vulnerable. They said they had recruited a marketing specialist who would manage most of their ads internally moving forward and would give consideration to the ASA’s comments.
Assessment
Upheld
The ASA acknowledged that Christmas was an expensive time period when people might struggle to cover additional costs such as buying gifts to celebrate Christmas Day. We also acknowledged that Family Vision had processes in place to check the affordability of their credit agreements for each customer and asked customers to inform them if they were experiencing financial difficulties. However, as with any credit provider, customers would be required to repay what they had borrowed, with interest, and there would be consequences if repayments were not made on time. We therefore focused our assessment on whether the ad presented Family Vision’s financial products responsibly.
The ad featured the claims “Christmas shopping just got more affordable… shop the gifts you want” and “Christmas shopping for all”. The ad also referred to purchasing iPads and included images of games consoles and a TV. The implication was that by using Family Vision’s credit products, consumers could purchase the products featured in the ad. In that context, the ad irresponsibly suggested people should use credit to purchase expensive, non-essential items as Christmas gifts. That was compounded by the claims “Christmas shopping for all” and “more affordable”, which would be understood as meaning that it would be beneficial for everyone, regardless of financial circumstances, to enter into credit agreements for non-essential and costly items. We concluded that the combination of claims and images encouraged consumers to use credit agreements to overspend at Christmas.
We acknowledged that Family Vision said the ad had been withdrawn. However, for the reasons stated, we concluded that the ad encouraged the use of credit agreements to fund Christmas spending in a way that was irresponsible and, therefore, breached the Code.
The ad breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
Action
The ad must not appear again in the form complained of. We told Family Vision Ltd to ensure that future ads did not irresponsibly encourage excessive spending through the use of credit, particularly in relation to Christmas spending.
