NZ Business Funder Facebook

Case [2023] NZHC 64


COMPLAINT NUMBER

23/064

ADVERTISER

NZ Business Funder

ADVERTISEMENT

NZ Business Funder Facebook

DATE OF MEETING

12 April 2023

OUTCOME

Settled

Advertisement: The sponsored Facebook advertisement for NZ Business Funder promotes that “Applications for The Official 2023 Small Business Relief Program are now open.”. The advertisement went on to provide more details about qualifying for the offer.

The Chair ruled the Complaint was Settled.

Complaint: This Facebook ad is misleading as it looks like it could be a govt approved recovery from Cyclone Gabrielle - when. Its simply an Australian loan company touting for business You pop details in & an email is then sent out inviting you to apply for a business loan. It's not until the application stage does the business revel who is the lender The ad is misleading as anyone can apply for the loans - they have no connection to. The Cyclone recovery & it takes 3 steps before you know who the lender is which Is dishonest.

The relevant provisions were Financial Advertising Code – Principle 1, Principle 2, Rule 1(a), and Rule 2(b)

The Chair noted the Complainant was concerned the advertisement was misleading as it was not clear who the advertiser was and it appeared to be an advertisement for government assistance.

The Chair accepted the complaint to go before the Complaints Board to consider whether the Advertising Standards Code had been breached.

As part of the self-regulatory process, Advertisers have the option of amending or removing their advertising to comply with the Advertising Codes. Upon receipt of the complaint the advertiser confirmed it had removed the advertisement.

Given the Advertiser’s co-operative engagement with the process and the self-regulatory action of removing the advertisement, the Chair said that it would serve no further purpose to place the matter before the Complaints Board.

The Chair ruled that the matter was Settled.

23/064

Chair’s Ruling: Complaint Settled


2

Details
AGLC
NZ Business Funder Facebook [2023] NZHC 64
Case
[2023] NZHC 64
Decision Date

CaseChat Overview and Summary

The case involved a complaint against NZ Business Funder concerning a Facebook advertisement that promoted applications for The Official 2023 Small Business Relief Program. The complainant argued that the ad was misleading as it appeared to offer government-approved recovery assistance for Cyclone Gabrielle, while it was actually a loan offer from an Australian loan company. The complainant further stated that the ad was deceptive because it took three steps before the identity of the lender was revealed, which they considered dishonest. The complaint was lodged under the provisions of the Financial Advertising Code, specifically Principles 1 and 2, and Rules 1(a) and 2(b). The Chair of the Complaints Board reviewed the complaint and accepted it for consideration by the Complaints Board to determine if the Advertising Standards Code had been breached.

The legal issues before the Complaints Board involved whether the advertisement breached the principles and rules of the Financial Advertising Code by misleading consumers regarding the nature of the offer and the identity of the advertiser. The complainant's primary concern was that the ad appeared to offer government assistance, which it did not, and that the process of revealing the lender was misleading and deceptive. The board had to assess whether the advertisement misled consumers by not clearly disclosing that the offer was from a private loan company and not a government initiative.

The Complaints Board, led by the Chair, concluded that the advertisement indeed breached the Advertising Standards Code as it was misleading about the nature of the offer and the identity of the advertiser. The Chair noted the advertiser's cooperation in removing the advertisement as part of the self-regulatory process. Given this voluntary compliance and the removal of the advertisement, the Chair determined that it would not serve any further purpose to bring the matter before the Complaints Board. Consequently, the Chair ruled that the complaint was settled.

The final outcome of the case was that the complaint was settled, and the advertiser had removed the advertisement from Facebook. The board did not proceed to make a formal decision on the breach of the Advertising Standards Code, considering the advertiser's voluntary compliance with the regulatory process.

Orders

Orders of the court

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Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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