Ad description
A TV ad, for Provident Personal Credit Ltd, featured an animated dog made from a folded bank note. The voice-over stated, "This is a Provident loan. It's a bit different. You don't have to go round the houses and you get to speak to a real person, because a Provident loan comes right to your door. So apply to borrow up to a thousand pounds and spread the repayments, just arrange for someone to call round ... Representative 399.7% APR ...". On-screen text throughout the ad stated "Representative 399.7% APR (fixed)".
Issue
A viewer challenged whether the ad, in particular the use of the animated dog, trivialised the process of taking out a loan.
Response
Provident Financial plc explained that the ad represented Provident's home collected credit product. They explained that, unlike other types of loan, home collected credit could not be obtained over the internet, which meant that a potential customer could not act quickly or thoughtlessly to obtain credit. First, they must contact Provident via its website or call centre. Their details would then be passed to a self-employed agent who would arrange a home visit or a series of visits to the customer's home to discuss the customer’s credit needs and potentially issue credit, once an affordability assessment had been carried out satisfactorily. Owing to legislation specific to the home credit market, before an agent could discuss credit "away from trade premises", Provident was required to obtain a "request to call" in writing, given on a prior occasion. This meant that on some occasions, an agent must pay at least two visits to a customer's home before credit could be issued. Provident required that at least 24 hours passed between the two visits, which acted as a cooling off period and made the product unsuitable for anyone seeking immediate financial relief.
Provident never imposed additional fees or charges for late, partial or even missed payments. In addition, Provident agents earned commission, not on sales, but on repayments, which encouraged cautious lending decisions. They believed the agent−customer relationship resulted in the creation of responsible loan arrangements which were responsive to a customer's circumstances.
Provident explained that focus groups during the campaign's development had identified the animated dog image with 'meaningful', 'loyal' and 'friendly' and that its size meant that customers felt in control. The dog was designed as a simple visual metaphor for the home credit product offered and the delivery process through which it was obtained. It was an animal associated with commitment and responsibility and was appropriate for the message Provident wanted to convey. Provident acknowledged that the music of the ad was upbeat, but believed it was low key and the voice-over was deliberately warm and personable, but measured and factual in tone. The use of an origami dog did invoke some humour, but the design and behaviour of the dog were carefully considered to avoid any implication that the process was a trivial one. The voice-over invited the viewer to arrange for a home visit, which emphasised the personal nature of the product and, when allied with the on-screen text "subject to affordability", mitigated against any suggestion of trivialisation. There were no references to speed or repeated use and the ad directed viewers to the Provident website, where full details of the terms of a loan, including a representative example containing a representative APR were available. The woman in the ad was depicted as sitting comfortably in her own home, demonstrably in control of her environment. There was no suggestion that credit was needed for any specific reason, that she had made a hasty decision or that she would use the loan for frivolous purposes. When viewed as a whole, and considering the legislative requirements in place for home credit products, Provident believed the ad was socially responsible and did not trivialise the process of taking out a Provident loan.
Clearcast said, in their view, the ad did not treat loans in a flippant way. It showed an animated dog made of money, but the animation was not cartoon-style or overly cute. They pointed out that the money did not jump into the person's pocket, instead a phone was handed over for them to make contact, so there was no implication of instant money or that there was no formal process involved. The voice-over stated "and you get to speak to a real person. Because a Provident loan comes right to your door", which implied face-to-face discussion, and the representative APR was seen throughout the ad, which made clear that the product was a loan which would need to be repaid and, therefore, something that required serious consideration.
Assessment
Not upheld
The ASA understood that the ad represented the advertisers' home credit product and that there were specific legislative requirements for this type of loan such that, for example, anyone who responded to the ad must first arrange a home visit with a credit representative as part of an affordability assessment before credit could be approved.
We acknowledged that the complainant was particularly concerned that the dog featured in the ad was 'cute' and that this trivialised the nature of the service offered. We considered, however, that while it might be seen as light in tone, with background music and an origami dog, the ad's content was not comic or juvenile. The dog was likely to be understood as metaphor for the advertisers' product and its journey through the ad as emphasising the 'delivery to the home' aspect of the service. There was no implication that a loan should be taken for frivolous purposes or that a decision to borrow should be taken quickly or without proper consideration. The ad explained factual information relevant to the service, for example the extent of a potential loan and the requirement for a home visit to be arranged. It also included a representative APR.
In consideration of the overall content of the ad, we concluded that it had been prepared with a sense of responsibility and was not in breach of the Code.
We investigated the ad under BCAP Code rule 1.2 1.2 Advertisements must be prepared with a sense of responsibility to the audience and to society. (Social responsibility), but did not find it in breach.
Action
No action required.
