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We acknowledged the Money Shop's and the agency's argument that the offer of £5 cashback for every £100 borrowed, payable when the loan was repaid in full on or before its due date, was not an incentive but rather a reward for good borrower behaviour. However, we considered that it was likely to encourage viewers to consider taking out a loan with that company and was therefore an incentive to apply for credit. We noted that the legal assurance from the Money Shop, upon which Clearcast had relied in approving the ad for broadcast, had treated the cashback offer in that manner.
We further noted that ads stating a rate of interest or an amount relating to the cost of the credit were also required, under Regulation 4(1), to include standard information by means of a representative example. Ads were exempt advance cash services cheyenne wy this provision only when Regulation 6(1) applied and the only rate of interest or amount relating to the cost of credit was the RAPR itself. We therefore understood that were the cashback african bank money loans not to be an incentive to apply for credit requiring (under Regulation 6(1)) the inclusion of the RAPR, and if the ad did not include any other triggers for the RAPR, the ad would have needed to include a representative example.
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 (". 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 advance cash services cheyenne wy, 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 a 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.