A poster for Sunny, seen on the London Underground network on 6 September 2017, featured an image of a man sitting in a deck chair wearing sunglasses and flip flops. Text stated “That’s life support … When you need some emergency cash, stress not”. Smaller text in the corner of the poster stated “Representative 750% APR”.
Two complainants, who believed the ad trivialised the decision of taking out a high interest loan by promoting a casual attitude towards doing so, challenged whether the ad was irresponsible.
Elevate Credit t/a Sunny Loans said that they acknowledged that taking out a loan was a serious decision. They said that the purpose of the ad was to highlight the fact that customers had five days to change their mind and could return the money without charge. They said that a combination of the phrase “that’s life support” and the image was used to ensure that customers remained calm and took a considered approach towards taking out a loan.
Sunny Loans said the ad was aimed to appeal to 35-year-old males. They said that the ad did not trivialise the experience of taking out a loan, but was encouraging customers to remain calm should they need emergency cash.
Sunny Loans said that the ad included other regulatory requirements such as the representative APR and information about late repayment. They said that the inclusion of those elements highlighted the serious nature of taking out a loan and the potential consequences of non-repayment or late repayment.
Exterion Media said that they did not consider the ad to be unsuitable for display because it included an advisory note regarding age restrictions and late repayments. They confirmed that they had not received any complaints.
The ASA considered that taking out a high interest, short-term loan was a decision that should only be made following careful consideration and that marketers should take care to advertise such products responsibly.
We noted that the ad prominently featured the text "emergency cash" as well as smaller text that warned of the risk of late repayment by stating "… can cause serious money problems". We considered that the text highlighted factors that should be taken into account when taking out a high-interest loan. We acknowledged that the ad featured an image of a man sitting in a deck chair, wearing flip flops and sunglasses. While we recognised that the image was likely to be interpreted as depicting an attitude of relaxation and relief, we considered that it was likely to be seen in the context of being able to access a loan at short notice, rather than endorsing a casual attitude towards taking out a high interest, short-term loan. For those reasons, we concluded that the ad did not trivialise the decision to take out a high interest loan and was not irresponsible.
We investigated the ad under CAP Code (Edition 12) rule 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Social responsibility), but did not find it in breach.
No further action necessary.