To: Directors, Brand Managers, Dealer Principals, Sales Managers
cc: Caira Day, Helen Redfern, Katy Smart

From: Jeremy Cuff/Jason Lewis/Claire Ellis and Steve Mawby

Date: 16 January 2012

SUBJECT: Group/F&I Marketing

Following on from the 'Group Marketing Topics' memo dated 18th November which focused on the “misleading aspects” of advertising, we thought it important to reiterate and recap the recent changes to consumer finance advertising which have been in force since February 2011.

The main points that must be adhered to when advertising credit are;

1) GENERAL INFORMATION ABOUT CREDIT ADVERTISING

If any 'Trigger' information is used in a piece of marketing, then the “full credit” advertisement format must be used.

Trigger information includes;

- Rate of Interest
- Any figure relating to the cost of credit e.g Monthly Payment, Total Amount Payable.

Showing just a Representative APR does not require a full credit advert.

2) FULL CREDIT ADVERTISEMENT

A Full Credit advertisement must include;

        Cash Price / OTR Price       
        Deposit
        Amount of Interest
        Interest Charges (if Applicable)
        Credit Facility Fee (if Applicable)
        Option to Purchase Fee (if Applicable)
        Term (e.g. 36 months)
        Monthly Repayments
        Annual Rate of Interest (i.e. Flat rate)
        Compounded rate if Interest (i.e APR)

3) REPRESENTATIVE APR

The Representative APR can be shown alone on an advertisement, but must represent the APR that a minimum 51% of customers get on that offer.

It can be used in place of a Full Credit advert if any of the following is used, but remember any trigger information would mean a full credit advert;

        Any incentive (e.g. 50/50, buy now pay later, Low Rate, FDA)
        On the Road Price (OTR)
        Deposit Details (FDA or otherwise)
        Amount of Finance
  
4) 0% FINANCE

The rules apply to all credit advertisements - 0% is NOT exempt.

5) PROMINENCE

The Representative APR must be more prominent than any other trigger information.

The details in the full credit advert must be all of equal prominence, but less prominent than the representative APR.

6) ILLUSTRATION/PHOTOGRAPHY

Any images of the car must be the exact model for which the finance has been calculated, even down to met paint in the OTR Price.

7) CONTACT DETAILS

The advertisement must include either the full name and postal address of the dealership advertising the credit and the name of the company providing the credit. The only exemption to this rule is “on site” advertising, radio or TV.

8) SMALL PRINT

Finally the advert still must include the minimum finance small print (e.g. Finance subject to status, 18 or over, T & C's apply, written quotations upon request etc)

Please remember that the above rules include all forms of advertising from newspapers, mail shots, internet offers and even demonstrators and vehicle signwriting.

The only exceptions being finance clearly marked for Business Purposes only or Contract Hire/Personal Contract Hire which again must be clearly marked. A £199 a month on a side of a car is not allowed, it must clearly say that it is on Personal Contract Hire (and therefore the customer never has ownership).

A guide to the changes in the Consumer Credit Act was emailed to all the Brand Managers and Sales Managers last autumn. If you have not received this, require another copy or need any further help or information please contact Jason Lewis at Platinum Financial Solutions.