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They said the ad pointed customers in the direction of the online channel. Clearcast said their general view was that the costs associated with quick loans ringgold road east ridge tn lending meant that it should only be considered as a last resort and not as wells gargo personal loan everyday form of borrowing, and they did not approve broadcast ads which suggested payday loans were suitable for discretionary spending.
They felt that the ad in question, including the reference to "life's little ups and downs", was consistent with their general approach, which was to approve treatments referring to payday loans as suitable for unexpected expenses. They said there was no suggestion in the ad that a payday loan should be undertaken quick loans ringgold road east ridge tn frivolous or non-essential reasons, but rather that it might be an option for those who needed money to deal with an emergency situation.
The Money Shop and the agency disputed whether the cashback offer was such that it required, under the Consumer Investex personal loans (Advertisements) Regulations 2010 ("the Regulations"), the inclusion of the RAPR in the ad with greater prominence than the offer. They considered the promotion was a reward for good borrower behaviour in the case that a consumer chose to take out a loan, rather than an incentive to apply for credit.
They said, however, that if the promotion was considered to be an incentive to apply for credit they considered that the ad would nevertheless comply with the Regulations and the BCAP Code because the RAPR was more prominent than the trigger for its inclusion (in this case, the incentive).
They said the RAPR was shown in a larger font size than the text "£5 Cashback for every £100 borrowed" and appeared for over a second longer.
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