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Dishonest Advertising
OFCOM Campaign
Ocean Finance


This is the transcript of my exchange with OFCOM on the Ocean Finance advertisement complaint. It forms part of an umbrella article on dishonest advertising which you can find here.

Complaint submitted at OFCOM's website on 7.8.4:

Ocean Finance claim that their loan rates are competitive, yet the inconspicuous text mentions a typical APR of 10.7% variable - which is not even close to being competitive.

So, the ad is misleading as well as being hugely annoying.


We have checked the advertising but don't believe we can pursue this matter any further. The commercial is not claiming to be the cheapest but is offering credit to a range of consumers including those who may have been refused finance elsewhere because of their circumstances. The rates clearly appear on screen so potential consumers are aware of the costs invloved. Also, it's very likely that most viewers will shop around and compare rates for themselves. Individual circumstances will vary and for some consumers the rate will be appropriate for their situation.

Thank you for taking the trouble to give us your views. We have not received any similar complaints and we don't beleieve on current evidence that viewers are being misled by the use of 'competitive'.


Gary, regarding your rejection of my complaint ref 2255959,
I agree with almost all that you said,
but none of what you said seems to address my complaint.

Yes, it's not claiming to be the cheapest - no one said it was.
Yes, clearly, it's targetting those with a poor credit history.
Yes, the rates are on screen. And yes, most people will shop round.
With respect - none of that addresses my complaint.

I am saying that Ocean Finance are making a false claim.
They are saying that rates are competitive, whereas in fact, their rates are poor.
They may be the best you can get if you have a dreadful credit history - but that is not the claim they are making.
They simply say that rates are competitive. That claim is simply not true.

Can you look at this again, please?




Thank you for your further email addressed to Gary Trott. Gary has passed it me me to review this case and I have also discussed it with our Advertising specialists.

As we have said before, we don’t judge claims in isolation from the overall context and what the most likely viewer interpretation will be. We have not received any complaints at all from people who have taken out loans with Ocean Finance. Individual circumstances will always vary considerably, and it is clear from what people say in the advertisements that Ocean Finance is willing to consider loans to people who may not qualify for an ordinary bank loan because of other debts or their credit history. The rate offered and the terms will matter far more to individual consumers as they shop-around. We would have received many more complaints if consumers felt they were being misled into taking out their loan at one rate when a lower rate was likely to be available to someone in their circumstances. The claim to be offering a ‘competitive’ rate is relative to individual circumstances and we think this is understood.

I’m afraid that we don’t see grounds for changing our view of this advertising.

Yours sincerely
Elfed Owens


Thanks for the prompt reponse, Elfed.

I understand your "wholistic" approach in trying to see the entire situation, rather than in looking at the claims in isolation. And I see why you ask the question "would people, in general, be misled" rather than "Are these claims strictly true".

But I think that your approach adds your own personal interpretation where none is necessary.

It seems to me that if the claims are all correct, then the ad should be allowed, and if not, it shouldn't.

There is little doubt in this case, that Ocean's claim on conpetitive rates is wrong - at best ambiguous, and that is a slippery slope we just don't need to go down.

Still, we'll have to agree to disagree, although I'll campaign to get this changed.

Thanks & Regards,


Thanks Mr Wesley. The government is looking at the way all kinds of financial products are marketed and this may well influence advertising in due course. We do recognise that there will be consumers who are both naïve and vulnerable but we honestly don’t have evidence that viewers are being misled by the Ocean Finance advertising

A lot of this is in flux with our move to the ASA, and you can find more information on the ASA web site: www.asa.org.uk. Parliament gave formal approval for the move very late in the day and the ASA is having to move into new premises by 1st November. We’re hoping the transition will be as smooth as possible but we are starting to advise people that their complaints may receive an ASA reply. The structure of the ASA is very different from Ofcom and this may address some of your concerns about interpretation of cases.


Elfed Owens



I really appreciate your patience and continued willingness to explore complaints with me.
Good luck in your move to ASA.

I have been updating my Let's Fix Britain article on my work with OFCOM and will notifiy you when it is complete, in case you want to add OFCOM's slant on things, or correct me on matters of fact.


If you would like to comment to OFCOM on their decision in this case, you can email them &Subject=OFCOM stance on Ocean Finance'>here.

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