Facebook is full of financial service advertising (including financial advice and debt management) where the financial service isn’t identified, and even the advertisers may use a false name.

If these advertisements are misleading – and some are – it can be very difficult to identify the name of the advertiser, or the business/es that are providing the advertised services.  

See examples here , here and here.

The idea is simple.  A big claim – often misleading -– claiming you can cut many years off your mortgage, qualify for a government program, get more from your superannuation or qualify for a debt reduction program.   You may need to “apply before” a certain date so you “don’t miss out”.

If you click for “more information” or “apply now”, you are asked to provide personal information and contact details in order to receive information or find out if you “qualify”.  Even then, you are unlikely to find out anything about the claims in the ad, but you are told that someone will contact you.

Until you are contacted by the financial service, you don’t know who they are – or what they are offering – which may be somewhat different from what the ad claims.

Inappropriate financial services that don’t meet the individual’s needs cause significant loss, and the information gap between consumers and experts contributes to the risks.  Lead generation increases that information gap further.  One party holds personal information about the consumer.  The consumer doesn’t even know who holds that information and what service is on offer.  

The consistency principle also applies.  Research has shown^[1] that if an individual agrees to a small request (for example providing personal information) they are likely to be compliant with a larger request (for example signing a contract).

It’s also likely that some of the financial services businesses wouldn’t make the claims made in the ads if they had to put their names to it, which increases the likelihood of inappropriate claims.

Any advertisement for a financial service should include the name or licence number of the business/es that may be providing the service and this should be in a direct link from the advertisement.  

Lead generation further unlevels the playing field making consumers more vulnerable to poor decisions.    We should be told the name of a financial services business before being asked to share any personal information – and if an advertisement is leading consumers to a financial service, that service should be prepared to “own” the representations being made.

ASIC’s RG234 ‘Advertising financial products and services (including credit): Good practice guidance’ is 10 years old, and a review could consider the impact of social media advertising, and in particular, lead generation.   

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^[1] Freedman, J. L., & Fraser, S. C. (1966). Compliance without pressure: The foot-in-the-door technique. Journal of Personality and Social Psychology, 4(2), 195–202. https://doi.org/10.1037/h0023552