The Office of Trading announces their revised guidance for fee-charging debt management companies surrounding internet marketing

The Office of Fair Trading (OFT) today, Thursday 22 March 2012, issued  its revised guidance for fee-charging debt management companies.

Debt Resolution Forum, training, monitoring and representational body for the industry, welcomed the new guidance and applauded the OFT’s decision to step back from banning the use of sponsored links and social media by debt firms, but remained concerned about the impact of the guidance on other areas of internet marketing.

Commenting, David Mond, DRF chairman and CEO of ClearDebt, said:

“The OFT’s consultation document made it clear that the OFT thought Twitter and Facebook were “unlikely to be an appropriate means of providing consumers with sufficiently balanced and adequate information”. In our response to the consultation and in conversation with the OFT DRF disagreed, believing that micro-blogging and sponsored links are only a signpost to a page offering a service. This page, DRF agrees, must be transparent and compliant.

“The new guidance reflects this and not just in relation to the internet, stating that the degree of detail required in various marketing messages  “will be applicable, in varying degrees” dependent on the circumstances  and is an important step forward.”

DRF is concerned that the guidance continues to include reference to the use of inappropriate keywords in internet search, whether paid for (PPC) or not, as an “unfair or improper practice” and extends this to terms “even if allowed/suggested by internet search engines. DRF believes that debt solutions firms that take pains to avoid misleading terms and which use landing pages which are fully transparent, clear as to the nature of the organisation and otherwise compliant cannot be held responsible for the natural search algorithms of major search engines like Google, or for the automated results produced by PPC advertising. DRF will continue it’s dialogue with OFT on this point.

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Note for Editors


3.13 – “The OFT considers that search engine sponsored links and online messaging services which limit thenumber of characters are unlikely to be an appropriate means of providing consumers with sufficiently balanced and adequate information”. DRF believes this guideline is unreasonable.

First, sponsored links are just that. Links. No one will enter any sort of arrangement with a debt resolution organisation unless they click on thelink and obtain information from the page to which the pay-per-click advertisement is linked. If that page is compliant then there should be no issue. The same goes for promotional messages on character-limited social networking services. Consumer action is only precipitated if the link is followed and it seems fair to DRF that links from promotional messages of this type should be to compliant pages.

In addition, it should be noted that any search links are contextual and therefore are targeted to the intent of the user, making them unlikely to be inappropriate.

We draw attention to our comments above that social and business networking sites on the internet are not only used for promotional purposes but also as networking tools for a variety of purposes and we believe a clear distinction needs to be drawn between paid-for social media and ordinary day-to-day use of social media by licensees.

For further comment, please comment:

DRF spokesperson, Andrew Smith

Tel: 0161 968 6825

Mobile: 0791 240 7532


Twitter:@Andrew_F_Smith, @DRF_UK


Sally Hardiman

Tel: 0161 969 2023


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