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The Lords mustn’t miss the chance to treat payday ads like gambling or alcohol

The Lords mustn't miss the chance to treat payday ads like gambling or alcohol

The Lords mustn't miss the chance to treat payday ads like gambling or alcohol

Payday lenders want to financially groom the next generation of borrowers. They’ve plastered their adverts on children’s TV channels and family TV shows, used puppets and kid-friendly slogans, and even had people in Disney-esque costumes handing out lollipops in the streets.

These ads pressurise parents with pester power

This is a danger for our entire society. It pressurises parents with pester power, in our poll one in three parents reported that their under-10s had repeated payday loan slogans, and 14% shockingly said that when they had refused to buy something, their under-10 nagged them to go to a payday lender.

One five-year-old even asked for money from Wonga as a Christmas present from his parents. This is no surprise, as the number of these adverts seen by children increased from 3 million to 596 million in the four years to 2012 alone.

They normalise this niche lending for the next generation

Yet more damaging is the fact that they normalise this type of niche borrowing for the next generation – inuring them to the livelihood damage this type of high-cost lending can cause.

The House of Lords has a chance to stop this

That’s why this Wednesday we need members of the House of Lords to grab the opportunity to back an amendment to the Consumer Rights Bill which would put restrictions on payday loan advertising, similar to those for gambling, alcohol, tobacco and junk food.

Specifically, it would ban payday TV and radio ads before the 9pm watershed – according to Ofcom research, this is when the majority of such ads are broadcast. A second amendment would stop firms cold calling people to offer payday loans.

Many of us have been campaigning on this for years, naming and shaming the payday lenders. Thankfully that pressure has started to have an impact – for example, payday lender poster boy Wonga has pulled its puppet adverts and is taking its sponsor logo off children’s Newcastle United replica shirts.

Yet this isn’t enough. There’s a lot of unprincipled money being spent in this area – and we can’t rely on lenders’ goodwill, we need legislation to cut it dead and protect our children.

Those whose job is to protect young people’s interests are vocally behind this too – the Children’s Society is a prime lobbyist for this ban and a joint report between it and debt charity StepChange recently showed how family debt causes children to suffer from worry and anxiety, experience bullying and miss out on the basics of life.

A third of children surveyed by the Children’s Society found payday loan adverts to be fun, tempting or exciting – and this group were much more likely to say they would consider using a payday loan in the future. 

The growth of the payday loan industry is frightening. It didn’t exist at any scale seven years ago. It’s a self-manufactured industry built by technology, marketing and advertising. It has made billions based on lending without a care, at wince-worthy cost, regardless of affordability, and snatching back cash heedless of the effect on the borrower. 

Thankfully some of the industry’s nastiest tricks – such as using recurring payments to snaffle every penny coming into people’s bank accounts day after day – have been regulated away. However, the Government’s sloth, failure to heed warnings and laissez-faire market policy means millions have already been burnt. Its belated but welcome regulatory volte-face only came after campaigners and other parties started making political capital by attacking such lenders.

Since then the regulator has kicked into action – write-offs of millions by Wonga as part of the supposed cleaning up of its act, fines for sending threatening fake lawyers’ letters and thankfully, soon, new limits on charging, though these are not quite as stringent as I’d have preferred as people still risk paying back twice the amount borrowed. 

Of course, you can’t solely blame irresponsible lending – we need responsible borrowing too. This year financial education joined the English National Curriculum and that should help, but it’ll take time. And it won’t help adults who already lack financial capability, are vulnerable or have mental health or capacity issues.

We also need to promote alternative ethical borrowing – through credit unions, using (the sadly much-reduced) Government Social Fund loans, and of course, better budgeting to avoid the need in the first place. 

The Church of England has valiantly vowed to try and compete lenders out of business by opening credit unions in churches. However, much payday lending is a technology play as well as financial, targeting people’s impulses (sometimes late at night when they are drunk watching gambling programmes) for instant cash.

The Church can’t, and won’t, compete with that. Nor should it offer to lend to people who can’t afford to repay. But some payday lenders do, knowing they can use hard-core tactics to get money back.

So we cannot allow the good being done in financial education and capability work to be wiped out by powerful multimillion pound payday loan ad campaigns. We’re already at a dangerous point in the growth of payday loans – if it goes on unchecked, just imagine the dystopian future in 10 years.

A staggering 10,000,000 now on the Martin’s Money Tips weekly email list – thank you

A staggering 10,000,000 now on the Martin's Money Tips weekly email list

A staggering 10,000,000 now on the Martin's Money Tips weekly email list

In 2002 I began to send tips to my friends, as and when I spotted a good deal, and jokingly used the subject line ‘Martin’s Money Tips’. It went to about 40 people and it was only done when I discovered some info I couldn’t use in my then Sunday Express column, or on Open House with Gloria Hunniford.

 

A couple of months later I was at a party and people I’d never met before were thanking me for the emails. It turned out my friends were forwarding it to their friends (this was before most people had heard of the word ‘viral’).

To make it easier, I set up an email list built around a basic homepage so anyone could get the info.

The email grew quickly and soon hit 1,000 recipients. I decided the site had potential to help me promote my journalism work, so I paid a web designer in Uzbekistan £100 to design a more professional version. This was launched on 22 February 2003, which I count as the moment this site was born.

Fast forward to yesterday when…

The 10,000,000th email address was opted into the weekly email list. Quite simply a staggering number. I can quite genuinely tell you I never thought it’d get this big, in fact this is a quote from my 1,000,000 receiving the email blog in 2007:

“As I mentioned to the MSG on Saturday, I actually felt a little depressed, I’m now not sure what the target should be. I’m very numbers driven, as I’ve discussed in a past blog. I am obsessed by looking at the email list graph. Now I don’t really know what to do. The next obvious target is 10,000,000 yet actually I believe that’s beyond the capacity of any website, as it’s simply too high a proportion of web adults. So what do I base it on next? Without a number to go for I’m slightly lost –- stupid really as I should be over the moon, but being the slightly nerdy chap I am, I don’t know where to go next. Suggestions welcome.”

NB. For those wondering, the MSG was the ‘Money Saving Girlfriend’ – who I now refer to (in blogs – not in person) as Mrs MSE – and of course this was long before Baby MSE came along.

I still write the email personally most weeks (it says when it’s not me) and I go through every word, though now I’ve a big and talented editorial team working with me and doing the research, writing the guides, and making creative decisions. But they’ll tell you I’m a bit of a stickler when it comes to the email, quite pedantic, change a lot (too much in their eyes) and am an all over email diva.

Yet I hope that’s paid fruition, the progression has been truly remarkable…

The growth stats

For my fellow stats nerds here’s the progress chart for the weekly email (it includes links to the waybackmachine. However sometimes images go missing from old versions of the site, so to help improve that, I may have linked to version of the site that are a few days off).

  • August 2002… Home Page. I launched the site as a personal home page… See what it looked like.
  • 22 February 2003… The Site’s Birth. I had the site developed into the first version of what it is today… See what it looked like.
  • 25 April 2003… 10,000 on the email list. See what it looked like.
  • 11 January 2004… 50,000 on the email list. See what it looked like.
  • 30 July 2004… 100,000 on the email list. See what it looked like.
  • 28 April 2005… 250,000 on the email list. See what it looked like.
  • 3 March 2006… 500,000 on the email list. See what it looked like.
  • 24 February 2007… 1,000,000 on the email list. See what it looked like.
  • 20 April 2008… 2,000,000 on the email list. See what it looked like.
  • 19 September 2008… 2,500,000 on the email list. See what it looked like.
  • 20 August 2010… 5,000,000 on the email list See what it looked like.

As I’ve explained in past blogs 10 million email addresses doesn’t equate to 10 million people. Some are duplicates and some are duds. We send to around 7.7 million live emails a week. I just use the total figure as it’s the most consistent for long term progression and I didn’t have other measures in the earlier days, so the next target is perhaps to be sending to 10 million live addresses. Even so this is quite a momentous day for the site.

I’d like to thank all the amazing advocates there are for the site out there. I constantly meet people who tell me they go on about MSE (and sometimes bore their friends to death) and recommend the email and the site. The team and I really appreciate that. It’s one thing to be passionate about your work, it’s a true accolade when many others share it. So thank you x 10,000,000.

Morally bankrupt: Payday lender Smart-Pig’s student targeted ad hides its 1,089% APR – I’m reporting it to the FCA and the ASA


While I was getting the lift to the tube over the weekend, I spotted a payday lender advert on the wall. I always scan these things to see how they try and sell their costly wares, and to check out the APR, but this time I couldn’t see it. I looked at the small print. Nope it wasn’t there – nor was there any mention of cost whatsoever.

So as the lift was about to arrive, I took this snap on my phone…

The Smart-Pig advert I saw

The Smart-Pig advert I saw

I went through to Smart-Pig’s site, which states it’s a 1,089% representative APR (it’s worth noting that even then its slider doesn’t change the APR when you change the borrowing, it’s just a fixed amount).

This is a disgusting practice and shouldn’t be allowed. It is a high cost credit lender targeting the youngest people able to borrow in our society and deliberately ignoring cost. The ad focuses on ease and competitions.

This should be stopped, so I’m going to do my best to stop it (with the help of MSE Wendy and MSE Aileen – my campaigns team). We’re going to formally complain to both the Advertising Standards Authority (ASA) and the financial regulator, the Financial Conduct Authority (FCA). The aim is to get this advert stopped and hopefully to punish Smart-Pig too.

PS. If you see an ad you don’t approve of you can report it to the ASA and the FCA via these links. 

How the ad breaches FCA and ASA rules

Here’s where we believe the ad is wrong (all credit to MSE Aileen for doing the research on this).

We believe it breaches both the ASA’s CAP code and FCA rules and we are going to report it to both authorities on the basis that…

ARGUMENT 1

The advert says:

Win a term’s rent – every customer is entered into our competition to win a term’s rent up to £3500"

The CAP Code says:

Offers of financial products must be set out in a way that allows them to be understood easily by the audience being addressed. Marketers must ensure that they do not take advantage of consumers’ inexperience or credulity." (Section 14.1)

The FCA handbook says:

A financial promotion must include the representative APR if it includes an incentive (including but not limited to gifts, special offers, discounts and rewards) to apply for credit or to enter into an agreement under which credit is provided." (CONC 3.5.7 (1) (b))

This advert is taking advantage of students’ financial situation and is trying to entice them to take a loan with a competition. The lender is clearly using this competition as an incentive for students to apply for one of its loans, so the advert should therefore show the APR, which it doesn’t.

ARGUMENT 2

The advert says:

Trusted by over 20,000 students"

The CAP Code says:

Subjective claims must not mislead the consumer; marketing communications must not imply that expressions of opinion are objective claims." (Section 3.6)

The FCA handbook says:

A firm must ensure that a communication or a financial promotion is clear, fair, and not misleading." (CONC 3.3.1 (1))

And:

Examples of practices that are likely to contravene the clear, fair and not misleading rule include using false or unsubstantiated claims as to the firm’s size or experience or pre-eminence." (CONC 3.3.10 (5))

So what does "trusted" mean? Is this simply the number of students that have taken out one of these loans? If so, the lender should not draw the far-fetched conclusion that every customer trusts it. If there really is an element of trust, so if the lender conducted a survey, what were the results? Where is the source on this ad?

ARGUMENT 3

The advert says:

Manageable limits – borrow up to £350 until your next student loan. Pay back early, extend and even top up your loan."

The CAP Code says:

Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner." (Section 3.3)

The FCA handbook says:

A financial promotion must include the representative APR if it includes an incentive (in the form of a statement about the speed or ease of processing, considering or granting an application, or of making funds available) to apply for credit or to enter into an agreement under which credit is provided." (CONC 3.5.7 (1) (c))

The lender is trying to persuade students to take out one of these loans because of the features mentioned in the last sentence. It is suggesting these features are unique to this lender, but in fact any consumer can do this, no matter what loan they take out.

And as the lender has failed to include the representative APR, we believe it’s breached two FCA rules – one where the competition is an incentive, and this incentive where it’s suggesting it’s easy to borrow more.

ARGUMENT 4

The advert says:

We know student money"  "Loans for students"

The CAP Code says:

Marketing communications must be prepared with a sense of responsibility to consumers and to society." (Section 1.3)

The FCA handbook says:

A firm must pay due regard to the interests of its customers and treat them fairly." (PRIN 2.1.1 (6))

The whole advert is aimed at students, persuading them to get further into debt. It’s socially irresponsible for the lender to be targeting students who are already managing so much debt.

The Smart-Pig website

The Smart-Pig website

How much is a blank worth at Scrabble?

How much is a blank worth at Scrabble?

How much is a blank worth at Scrabble?

I’ve been getting the spreadsheet out. Over the weekend Mrs MSE and I played a few games (as we do). In the first two she was rather unlucky that I got both blanks each time, which I think probably turned the game in my favour (just). Thus intrigued, I decided to enter nerdvana and calculate the value of each blank.

Of course, a blank, in simple terms, is the only tile on a Scrabble board worth no points. Yet what I’m talking about is the value of gaining a blank – the fact it can be used as any letter makes it by far the most powerful, flexible and desirable tile there is.

So on to the calculation. Luckily, I’m not doing this blind. I’ve been keeping a spreadsheet of the last 948 of the 965 games of Scrabble Mrs MSE and I have played since we met – plus since game 690, I’ve been recording how many blanks we got in each game too. That means I now have just over 250 games with that data – a decent enough sample – so I decided to see how it pans out.

Me Mrs MSE
Games with 2 blanks 51 52
Average score 444.9 391.8
Games with 1 blanks 156 156
Average score 415.6 378.0
Games with 0 blanks 52 51
Average score 399.5 354.9

As you can see, the number of blanks has a clear impact on the score in a game.

This is, of course, for regular Scrabble players, who get a decent number of bingos (7-letter words). I suspect for new players, the difference will be far less as then the gain of being able to use a blank for bingos is offset by the fact it’s a non-scoring letter.

Typically for both of us it’s worth 23 points. Though there is a difference in the distribution. For me the second blank is worth far more – probably because I tend to play harder when I’m on for a very good score. For Mrs MSE the first blank is worth more, probably as she cares less about her ‘ongoing average’ than I do, so she takes her foot off the gas if she’s behind and likely to lose.

Related Past Blogs:

How would you describe Lidl? Is it really “poor food for poor people”?

How would you describe Lidl? Is it really “poor food for poor people”?

How would you describe Lidl? Is it really “poor food for poor people”?

The papers were full of it yesterday on the back of Lidl announcing sales of premium vintage and non-vintage wines such as Châteauneuf-du-Pape. All the messages were on about posh goods next to the usual tat. The phrase that came up time and time again was that "the firm is trying to move away from its poor food for poor people image".

I found this interesting, as I think it’s perhaps a legacy of a long-gone time. It’s not close to how I would characterise Lidl (or Aldi) and so I’m interested to find out if this is a true reflection of the general perception of Lidl, both among those who shop there and those who don’t.

Certainly a basket of shopping at Lidl can be very cheap. True too is the fact that it is used by many as a place to cheaply stock up on your bog roll and necessities – with a catch-up shop for the other stuff done at the main supermarkets. Yet for me this is less about quality of food and more about the range of choice.

I would categorise both Lidl and Aldi as ‘limited brand’ supermarkets – when you shop in them, you don’t necessarily get the brands you are used to, nor do you get the great plethora of options for each food item that you do elsewhere.

Instead, you get a limited choice of own brand and other brands – far fewer options of your tinned tuna than in a large Tesco store. But this is the defining point – a limited number of choices doesn’t necessarily limit quality.

So my question, which I’d love you to feedback on below is; what is YOUR perception of Lidl and Aldi? And do say whether you shop there or not.