Because the cashback offer constituted an incentive to apply for credit, the RAPR needed to be communicated with greater prominence than the offer itself. The offer was included towards the end of the ad in both the voice-over quick decision loans online. when you pay back in full on your original due date, we'll give you £5 cashback for every £100 you borrow") and in bold text in a large yellow circle that appeared on-screen ("£5 Cashback for every £100 borrowed"), whilst the RAPR was stated only in text at the bottom of the screen.
Although we noted that the ad should be taken as a whole, we considered that information given in quick decision loans online voice-over would generally be seen by consumers as being more prominent than on-screen text at the bottom of the screen, and that on-screen text at the bottom of the screen was therefore unlikely to be sufficiently prominent if the triggering information was given in the voice-over, or both in the voice-over and on-screen.
We also noted that, while the RAPR was written in a larger font size than the cashback offer and was displayed for slightly longer, it was not shown at the point that the cashback offer quick decision loans online introduced, or at any point thereafter, and that the cashback offer was presented in the main part of the screen within a bright yellow circle whilst the RAPR was not. We considered that that had the effect of making the incentive to apply for credit stand out more to viewers than the information it triggered.
We therefore concluded that the RAPR was not given bendigo bank cash advance fee prominence in the overall presentation of the ad than the cashback offer which triggered the requirement for its inclusion, and that the ad breached the Code. On that point, the ad breached BCAP Code rule 14.
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