Background
Misleading Advertising: Person(s) unknown t/a “Changes in Debt”, “Changing Debts”, “Change Debt” and "Money Advice Debt Help" breaks the UK advertising rules for misleading claims for their debt management lead generation websites; https://changesindebt.co.uk/, https://changingdebts.co.uk/, https://changedebt.org/ and https://moneyadvicedebthelp.co.uk/.
“Changes in Debt” and "Money Advice Debt Help" claim to be based at: Freckleton Business Centre, Freckleton St, Blackburn BB2 2AL and Merchants Court, 2-12 Lord St, Liverpool L2 1TS. Since January 2023, “Change in Debt” also uses the trading styles “Changing Debts” and “Change Help For All” on the https://changesindebt.co.uk/ website. “Changing Debts” claims to be based at: 2 Wellington Place, Leeds, LS1 4APH. “Change Debt” claims to be based at: Suite 7 6th Floor, 120 Bark St, Bolton BL1 2AX.
These websites are being considered together because enquiries to “Changes in Debt” receive responses from “Money Advice Help”, a previous website which was taken down in January 2023. The websites appear to be made from templates and similar versions go live and disappear. The websites do not offer insolvency practitioner services in-house, but appear to acquire leads for third party insolvency practitioners.
The ASA has published several rulings about ads which offered consumers a way to write off debt in government approved schemes. These ads were not placed by FCA-authorised debt advisers but by lead generation companies or insolvency practitioners, and ultimately advertised services for individual voluntary arrangements (IVAs) [in England, Wales, NI] or protected trust deeds (PTDs) [in Scotland].
In June 2022 we published our Enforcement Notice - Debt management ads by insolvency practitioners and lead generators. Insolvency practitioners and lead generation companies which ultimately advertise an IVA/PTD service must be extremely careful to ensure their advertising is responsible and does not mislead.
The https://changesindebt.co.uk/, https://changingdebts.co.uk/, https://changedebt.org/ and https://moneyadvicedebthelp.co.uk/ websites breach the Notice because they do not include a clear and prominent statement that they are a lead generation company which will pass on customer leads to third parties.
The CAP Compliance team contacted Person(s) unknown t/a ““Changes in Debt” / “Changing Debts” / “Change Debt” / “Money Advice Debt Help” and, in the absence of a substantive response, first took the decision on 18 November 2022 to place their company details on this section of the ASA website. On 30 November we added a further website called “Change Helpline” when this was brought to our attention. On 23 January 2023 the websites were reviewed, and “Change Helpline” was no longer live. There was also new disclaimer text on “Changes in Debt”, which was an improvement, but not sufficient to comply with the Enforcement Notice. This listing was amended accordingly. On 2 February we amended the listing to remove “Money Advice Help”, which had been taken down, and add the new websites “Changing Debts” and “Debt Helplines”. On 7 February we added “Change Debt”. On 8 March we amended the listing to remove "Debt Helplines" and add "Money Advice Debt Help".
These website details shall remain in place until such time as Person(s) unknown t/a “Changes in Debt” / “Changing Debts” / “Change Debt” / “Money Advice Debt Help" has appropriately amended the https://changesindebt.co.uk/, https://changingdebts.co.uk/, https://changedebt.org/ and https://moneyadvicedebthelp.co.uk/ websites to ensure compliance with the CAP Code.
