Ad description
Two TV ads for Cover Today, a provider of life insurance:
a. The first ad, seen on 25 October 2022, featured a woman on a walk with her family who said, “I decided to learn more about over 50s life insurance from Cover Today. They’re the only over 50s life insurer with no waiting period, unlike other insurers who could make you wait up to two years. With Cover Today you’re fully covered from day one […] Cover Today are the only over 50s life insurer with no waiting period and no annoying trips to the doctors either […].”
The ad included two scenes which included on-screen text that stated “The only over 50s life insurer with no waiting period”. The final scene included on-screen text that stated “NO WAITING PERIOD”.
The ad included small on-screen text at the bottom of the ad that stated “Compared to current market providers of Over 50 Life Insurance only. Cover Today offer immediate cover for death due to any cause. Visit covertoday.co.uk/compare-over-50-life-insurance”.
b. The second ad, seen on 19 November 2022, featured a man sitting in a cafe who said, “I decided to learn more about over 50s life insurance from Cover Today. They’re the only over 50s life insurer with no waiting period, unlike other insurers who could make you wait up to two years. With Cover Today you’re fully covered from day one […].”
A voice-over stated, “Cover Today are the only over 50s life insurer with no waiting period, everyone else makes you wait up to two years. Get covered in minutes with no annoying trips to the doctor […]”
The ad included two scenes which included on-screen text that stated, “The only over 50s life insurer with no waiting period”. The final scene included on-screen text that stated, “NO WAITING PERIOD”.
The ad included the same small on-screen text at the bottom of the ad as ad (a).
Issue
Two complainants challenged whether the implication in the ads that Cover Today was the only over 50s life insurer to offer immediate cover was misleading and could be substantiated.
Response
Neilson Financial Services Ltd t/a Cover Today said that they were the only over 50s life insurance product with no waiting period. While other companies may have offered accidental death cover immediately, they all had a waiting period before the full benefit amount could be claimed for death by any cause.
They believed that the ads made sufficiently clear that the comparison related to when full cover (cover for death by any cause) could be obtained and did not inform or imply to viewers that other providers of over 50s life insurance offered no immediate cover. The ads focused on explaining the unique feature of Cover Today’s product; that consumers did not have to wait before a claim could be made, regardless of the cause of death.
The ads included a web address in the qualifying text which enabled viewers to verify the claims. It provided a comparison with the largest providers of over 50s life insurance in the UK market and directed readers to the Fairer Finance (a research and ratings agency that provided data on financial products) website which provided further substantiation.
They provided a link to the Fairer Finance ratings for over 50s life insurance and said that it showed Cover Today was the only provider without any waiting period before the full benefits could be claimed. The report also showed that numerous other providers required consumers to wait 24 months before death from any cause was covered. Although one provider operated a waiting period of 36 months, Cover Today referenced 24 months in the ads because they considered that it was a fairer representation of the market position. Cover Today also conducted their own internal research on a regular basis to ensure that marketing claims were accurate. They provided a copy of that research.
They acknowledged that the claims could mislead viewers by implication if they were not qualified. They therefore made sure to clarify that the comparisons referred to ‘full cover’.
They said that the Office of National Statistics stated that, in 2021, 2.13% of deaths in those aged over 50 in England and Wales were caused by an accident. Therefore, while other providers may have offered accidental death coverage from day one, the vast majority of claimants would not have received their full benefit amount if they passed away within their policy waiting period.
Clearcast said that they approved the claim “Cover Today are the only insurer to offer immediate cover” on the basis of Fairer Finance data that Cover Today supplied to them. They also provided a copy of that data.
They endorsed Cover Today’s comments that the claim was suitably qualified and made clear that it was referring to full cover, that other insurance providers only offered immediate cover for accidental death and not death by other reasons, and that the ads included a web address where the claim could be verified.
Assessment
Not upheld
The ads claimed that Cover Today were “the only over 50s life insurer with no waiting period, unlike other insurers who could make you wait up to two years. With Cover Today you’re fully covered from day one” and “Cover Today are the only over 50s life insurer with no waiting period”. Ad (b) also included the claim “everyone else makes you wait up to two years”. Both ads also included on-screen text that stated “The only over 50s life insurer with no waiting period” and “NO WAITING PERIOD”, as well as qualifying text that stated “Cover Today offer immediate cover for death due to any cause”.
The ASA considered that viewers would understand both ads to mean that Cover Today’s over 50s life insurance gave immediate cover for death by any cause, and that they were the only UK insurer which did so. Because the ads referred to being “fully covered” with Cover Today, consumers would likely understand that other insurers may give them some cover immediately but that it could take two years until they were fully covered.
We assessed the evidence provided. The Fairer Finance rating for over 50s life insurance rated a large number of providers taking into consideration how long after a policy started until the full benefits could be claimed. Cover Today’s internal research provided information on the waiting period for full cover to start for the same providers as those referenced in the Fairer Finance rating, as well as several others, which we understood covered the full market. Cover Today were the only provider that did not require a waiting period until the full benefits could be claimed. All other providers had a waiting period that ranged between 12 months and 36 months, although they did all provide cover for accidental death as soon as the policy started. We therefore considered that the comparative claims that Cover Today were the only insurer to offer over 50s life insurance with no waiting period for full cover to begin had been substantiated.
Therefore, because Cover Today were the only over 50s life insurer to offer immediate cover for death by any cause, we concluded that the ads were not misleading.
We investigated ads (a) and (b) under BCAP rules 3.1 (Misleading advertising), 3.9 (Substantiation), 3.10 (Qualification) and 3.33 (Comparisons with identifiable competitors), but did not find them in breach.
Action
No further action necessary.
