The Central Bank advises that it recently undertook a review of mortgage related advertising, with a focus on cash back incentives, to assess clarity and transparency for consumers.
A risk to consumer protection exists where consumers are not informed of all of the consequences of choosing a mortgage that offers short-term financial relief, including that it may cost the consumer more in mortgage repayments over the life of his/her mortgage than if he/she had chosen an alternative product.
Some 183 advertisements were reviewed for compliance with the advertising requirements in the Consumer Protection Code 2012 and the European Union (Consumer Mortgage Credit Agreements) Regulations 2016 (S.I. No. 142/2016). In some cases, the same advertisement may have appeared across all formats of advertising reviewed.
As a result of the review, the Central Bank instructed lenders to withdraw or amend c. 75% of the advertisements included.
In summary, the key findings from the review were:
- Key information and qualifying criteria was not always included in the main body of the advertisements, or indeed in the small print (e.g. whether a current account with the lender was required in order to qualify);
- The content of some webpages was not accurate and/or up to date; and
- The content of some of the advertisements was unclear (e.g. how the cash back incentive was calculated).
