The ASA has ruled that encouraging people to borrow money to make the most of the Black Friday sales was irresponsible.

A paid-for Meta ad for SteadyPay, a short-term loan provider, featured a woman waving a wad of £20 notes saying "Do you want something from the Black Friday sales, but worried you can't afford it? You need to get CashWave by SteadyPay."  The ad also referred to the simplicity of applying via an app and having a "soft" credit check.  A caption stated "Black Friday is here, and so are the deals – but are you financially ready? With SteadyPay, you get a £300 interest-free boost, split into 3 easy monthly payments. Grab what you want now, pay it off with ease!"

The ASA's investigation arose out of its Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules.  So there weren't any actual complaints about this. But the ASA challenged whether, by encouraging consumers to borrow money for the Black Friday sales and spend more than they could afford, the ad was irresponsible.

SteadyPay Ltd said the ad was intended to attract customers' attention to CashWave, a £300 three-instalment loan for which the borrower paid a monthly subscription fee of £30. The ad stated that credit was subject to affordability and status.  SteadyPay believed their risk engine widened access to credit to the underserved, without placing borrowers into a debt cycle. Their service was intended for people who had affordability but were rejected for loans by mainstream lenders because they did not have much credit history. They believed the fact that less than 5% of customers defaulted on their loans demonstrated that the service was intended for people who had affordability. SteadyPay said that they had stopped using the ad, informed the creative team about the complaint and had started to review their advertising.

The ASA said that the ads encouraged consumers to borrow money to purchase discounted products that they could not afford in the Black Friday sales. Although the ad did not suggest the type of products to purchase, they noted the Black Friday sales typically offered savings on predominantly non-essential products such as technology, beauty and clothing.

In addition, the ad put undue emphasis on speed and ease of access, as well as suggesting the loan would be "easy" to pay off. It trivialised the decision to take out a loan and made light of the consequences of borrowing.

Because the ASA considered the ad encouraged consumers to borrow money for the Black Friday sales to spend more than they could afford and made light of the consequences of borrowing, it concluded it was irresponsible and breached the CAP Code. It told SteadyPay Ltd to ensure that future ads did not irresponsibly encourage consumers to borrow money to purchase items that they could not afford, particularly in relation to the Black Friday sales.

In another ruling published the same day, the ASA told another advertiser to ensure that future ads did not irresponsibly encourage excessive spending through the use of credit, particularly in relation to Christmas spending.

The rulings indicate the importance of ensuring that advertising is socially responsible.  However, I do wonder if the ASA should be making value judgments about what is "non-essential" spending.