Background
This ad was identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.
Ad description
A paid-for Meta ad for SteadyPay, a short-term loan provider, seen on 13 November 2024, featured a video of a woman. The woman waved a wad of £20 notes at various points during the ad including, after applying on her phone in one hand, when a wad of notes appeared in her other hand. She said “Do you want something from the Black Friday sales, but worried you can’t afford it? You need to get CashWave by SteadyPay. With CashWave, you get £300 for 90 days to repay, spread over three equal payments”. On-screen text stated, “Repay Month 1, £100, Month 2, £100, Month 3, £100”. The woman also said “Simply apply for CashWave on the SteadyPay app and after a quick soft credit check, if you’re eligible, you’ll be able to withdraw £300. Life doesn’t wait for payday. Download and apply for CashWave now”. Further on-screen text stated “APR 91.26%”. Small print seen throughout the video stated, “Credit subject to affordability and status, for over 18s only. T&C apply. No interest fees. Representative example: amount advanced £300. Interest charged: 0%. Subscription paid: £90 (£30 x3). Total amount paid: £390. APR: 91.26%”. A caption on the post stated “Black Friday is here, and so are the deals – but are you financially ready? With SteadyPay, you get a £300 interest-free boost, split into 3 easy monthly payments. Grab what you want now, pay it off with ease!”
Issue
The ASA challenged whether, by encouraging consumers to borrow money for the Black Friday sales and spend more than they could afford, the ad was irresponsible.Response
SteadyPay Ltd said the ad was intended to attract customers’ attention to CashWave, a £300 three-instalment loan for which the borrower paid a monthly subscription fee of £30. The ad stated that credit was subject to affordability and status. No applicant could access funds without being assessed by both SteadyPay’s credit risk engine and a credit reference agency. Before taking a loan, applicants received a fully regulated loan agreement and pre-contract information. SteadyPay believed that meant people who could not afford a loan were not offered one.
SteadyPay believed their risk engine widened access to credit to the underserved, without placing borrowers into a debt cycle. Their service was intended for people who had affordability but were rejected for loans by mainstream lenders because they did not have much credit history. The monthly subscription fee was only payable whilst the borrower had an outstanding balance, up to three months. If the borrower repaid the loan in fewer than three instalments, they paid lower subscription fees. Repayments were automated at 30-day intervals through a debit-card transaction. Customers were able to request extended payment periods through SteadyPay’s app. They believed the fact that less than 5% of customers defaulted on their loans demonstrated that the service was intended for people who had affordability.SteadyPay said that they had ceased using the ad, informed the creative team about the complaint and had begun a process to review their advertising.
Assessment
Upheld
The ad included the statements “Do you want something from the Black Friday sales, but worried you can’t afford it?”, “Life doesn’t wait for payday. Download and apply for CashWave now” and “Black Friday is here, and so are the deals – but are you financially ready?”. The ASA considered those statements encouraged consumers to borrow money to purchase discounted products that they could not afford in the Black Friday sales. Although the ad did not suggest the type of products to purchase, we noted the Black Friday sales typically offered savings on predominantly non-essential products such as technology, beauty and clothing. We considered that the reference to Black Friday, which was known to be the final Friday in November, with “Life doesn’t wait for payday” and “are you financially ready?” encouraged consumers to rush to take out a loan so that they did not miss out on the sales.
We also considered that statements such as “Simply apply for CashWave on the SteadyPay app and after a quick soft credit check, if you’re eligible, you’ll be able to withdraw £300” and “Grab what you want now, pay it off with ease!” put undue emphasis on speed and ease of access, as well as suggesting the loan would be “easy” to pay off. We considered those statements, alongside the video of the woman shown applying on the app with one hand and the money appearing in the other, trivialised the decision to take out a loan and made light of the consequences of borrowing.Because we considered the ad encouraged consumers to borrow money for the Black Friday sales to spend more than they could afford and made light of the consequences of borrowing, we concluded it was irresponsible.
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 SteadyPay Ltd to ensure that future ads did not irresponsibly encourage consumers to borrow money to purchase items that they could not afford, particularly in relation to the Black Friday sales.
