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ADVERTS for payday loans could be banned from pre-watershed TV after the UK's advertising rules watchdog announced a public consultation on the issue.
The Broadcast Committee of Advertising Practice (BCAP) have said that they are considering introducing "scheduling restrictions" on televised adverts for payday loans, amid rising concern that they cause harm by "exploiting" children or young people.
Charities such as the Children's Society and the Money Advice Trust have already submitted evidence calling for a pre-9pm ban on payday loan adverts.
"On the debt advice frontline we have become increasingly concerned that high cost credit is in danger of becoming normalised amongst young people," said Joanna Elson, chief executive of the Money Advice Trust.
"Restrictions on payday loan advertising before the watershed, on the same basis as those already in place for gambling and alcohol, would be a very welcome step," she added.
Research from the Children's Society suggested that more than half (56%) of children reported seeing loan adverts "often" or "all the time".
More pertinently, they also say that a third of children aged between 13 and 17 thought payday loan adverts were "fun, tempting or exciting".
Payday loan ads have been receiving a lot of attention in recent years.
In 2013 a group of MPs tried to get the adverts banned from children's TV.
This led the Government to ask BCAP whether there was any potential for a total pre-watershed ban.
While BCAP were looking at the content of payday loan commercials, some payday loan companies decided to do a little self-regulating.
In May, Wonga announced that they would ensure that their ads didn't appear on programmes that were watched by large numbers of younger people.
However, these promises didn't extend to complying with the watershed, or even refraining from advertising during prime time soaps - which are often watched by children, regardless of their mostly adult content.
The initial BCAP review concluded at the end of last year that the "light hearted, jovial treatments" in ads had the potential to trivialise the reality of payday loans.
However, they decided that there was no substance to the perception that "some payday loan ads inappropriately appeal to children", or that some ads were aimed at "encouraging children to ask their parents to take out a payday loan".
Following pressure from charities and research from Ofcom, BCAP decided to extend their review and asked for submissions of further new evidence.
But even so, they say that they've found "little robust evidence of advertising-related harm" and that the benefit of bringing in scheduling restrictions "have not been articulated".
BCAP do acknowledge that most of us would rather not see payday loan adverts on TV - indeed, they quote the Children's Society study suggesting that 75% of parents would support a pre-9pm ban.
They also acknowledge that a ban might not significantly affect the advertising revenue of the broadcasters.
But neither of these factors is enough to justify restrictions.
BCAP have sought further data from the Broadcast Audience Research Board (BARB), which allows broadcasters to identify programmes likely to appeal particularly to children and young people.
Unfortunately, they say that the data is inconclusive about whether younger viewers are being "meaningfully targeted".
BCAP say they're aware that there are "gaps... in the information available" to them and others investigating the impact of payday advertising, hence the launch of the public consultation into their effect.
Their findings are available to view here [pdf] - and people interested in responding should take a look at Section Nine.
This asks respondents whether they agree with one of the following three options regarding payday loan adverts:
The document linked to above also provides sets out guidance for submitting answers, and the reasoning behind them, as well as the contact details to which responses should be sent.
The deadline for submissions is December 16th.
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