Adverts and Satsuma loans - the singing satsuma and promotions under the spotlight
Recent adjudication from the ASA shows how important it is to ensure that all marketing and advertising is checked and signed off and an audit trail is available.
The ASA adjudication was on Provident Personal Credit Ltd t/a Satsuma Loans.
Three issues were investigated.
Two complainants challenged whether the ad was misleading because:
It did not state an APR; and
It did not include a representative example.
Another complainant said it trivialised the nature of the product advertised.
Assessment: 1. & 2. Not upheld.
"We considered that the content of the ad did not trigger the need for a representative APR example. Therefore, we considered that the ad was compliant with the Regulations and concluded that it was not misleading. On that point, we investigated the ad under BCAP Code rule 1.3 (Responsible advertising) and 14.11 (Lending and credit) but did not find it in breach."
3. Not upheld: "On that point, we investigated the ad under BCAP Code rule 1.2 (Responsible advertising), but did not find it in breach."
Full details of the singing satsuma judgmenet here
IFAC donâ€™t check against the BCAP code, but we may have to introduce this if more complaints come to light from ASA on regulated products.
You must get your promotions checked. Use Bat but any other system may do this as well â€“ it is foresight hindsight.
Using systems today to cover yourself tomorrow.