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(Responsible advertising). We st george bank refinance personal loan that, under Regulation 6(1)(b), credit ads must specify an RAPR if they included any incentive to apply for credit or to enter into an agreement under which credit was provided, and that that RAPR should be given greater prominence than the incentive (Regulation 6(2)).
We acknowledged the Money Shop's and the agency's argument that the offer of £5 cashback for every £100 borrowed, payable when the loan was repaid in full on or before its due date, was not an incentive but rather a reward for good borrower behaviour. However, we considered that it was likely to encourage viewers to consider taking out a loan with that company and was therefore an incentive to apply for credit.
We noted that the legal assurance from the Money Shop, upon which Clearcast had relied in approving the ad for broadcast, had treated the cashback offer in that manner. We further noted that ads stating a rate of interest or an amount relating to the cost of the credit were also required, under Regulation 4(1), to include standard information by means of a representative example.